renée - cornucopia institute · note to the file . subject: minutes of the us-eu organic working...

From: Gebault King, ReneeA - AMSTo: "[email protected]"Cc: [email protected]; Courtney, Cheri - AMS; Subject: OWG meeting minutesDate: Tuesday, May 24, 2016 8:37:00 AMAttachments: 160202 OWG DRAFT minutes USDA review.doc

Dear Manuel, Please accept my apologies for the delay in sending comments. Attached are the draft minutes fromthe 2 February meeting of the Organic Working Group. I appreciate your understanding. Kind regards,

Renée

Renée Gebault King, Ph.D.Accreditation Manager

Office: 202.690.1312 | Mobile: [email protected] USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South, Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

(b) (6)

(b) (6)

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 Office: L130, 5/224 - Tel. direct line +32 229-52127

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR AGRICULTURE AND RURAL DEVELOPMENT Directorate B. Multilateral relations, quality policy B.4. Organics

Note to the file

Subject: Minutes of the US-EU Organic Working Group Videoconference, 2 February 2016

Participants: Miles McEvoy, Cheri Courtney, Renée Gebault King (NOP), Kelly Strzelecki (FAS), Julia Doherty (USTR), Joao Onofre, Francesco Meggiolaro, Sergio Pavón González, Klaus Blank, Manuel Rossi Prieto (EC)

1. Plurilateral arrangement

A draft joint non-paper was discussed and finalised during the meeting. Comments on this non-paper had been previously exchanged between both sides.

Some points related to compatibility with WTO rules and to some language used were clarified. A roadmap was agreed to move forward. Regarding potential members, both parties agreed to share the responsibility to present/announce the idea to potential candidate countries, in particular those currently having equivalence arrangements with the EU and the US. US suggested to also include as potential candidates to some developing countries within Latin America (e.g.: Costa Rica). These exploratory discussions should take place in the upcoming months in view of a government-to-government (G2G) discussion that could take place after the summer in a "neutral" country like CH. CH could also be the ideal country to act as the secretariat of this process.

The agreed roadmap is the following:

February-April:

− USNOP will finalise the non-paper including comments made in this meeting and will send it to COM

− Both parties will launch internal consultations. US noted the need to consult the non-paper with stakeholders. EC explained that the non-paper has to be notified at EU level, according to transparency procedures.

− USNOP will suggest a preliminary list of countries to be contacted by each side.

− EC will informally contact CH at Biofach next week to explore their willingness to host the G2G discussion and to act as secretariat. CH has already shown a great interest on the plurilateral agreement.

2

− Videoconference EU-US by the end of March-beginning of April 2016 to follow-up.

April-July

− Exploratory discussions with equivalent third countries on non-paper

September-October

− G2G discussion in CH

2. US-EU trade arrangement questions

US will send an email with some questions.

3. Update on WTO TBT notifications

The EU-US joint notification was sent to WTO members. EC sent a draft joint notification to Canada and is waiting comments from the Canadian authorities. EC is preparing joint notifications regarding other mutual recognitions.

4. Update on ongoing US and EU equivalency negotiations

US and EC exchanged information on ongoing negotiations with third countries.

On Mexico, US informed that an on-site inspection will take place in March, and equivalence discussions will follow in April. The goal is to conclude negotiations by fall 2016. EC explained that it will try to close its negotiations immediately after and asked US to share the equivalency assessment.

On New Zealand, US has planned to carry out the equivalency assessment in 2017.

On Taiwan, US informed about a peer review that will take place in US in March. Not full equivalency expectedUS peer review audit proposed for early-2017 in Taiwan. Discussions will continue as US aims to ensure products access to Taiwan, and residue test and hold procedures at border are revised. EC referred to alternative solutions as the recognition of Taiwan's control authority.

On Chile, EC explained that negotiations are very advanced and a trade agreement (not an arrangement) is expected to be signed in 2016.

On Costa Rica, US confirmed interest in having equivalency recognition but there are significant concerns about Costa Rica’s lack of investigation and enforcement on fraudulent pineapple products and bananas production.

3

5. Update on ETKO

US informed about ETKO's appeal to the decision on withdrawing accreditation. The appeal has no suspension effect. EC expressed concerns about the long procedure needed in US to withdraw accreditation to this CB.

6. Update on EU review

EC explained the state-of-play of negotiations with the European Parliament and the Council. The Dutch Presidency of the EU has planned 6 "trilogue" meetings before July. The aim of the Dutch Presidency is to reach a political agreement in June. This is quite ambitious. Then some months would be needed to prepare the final text. The best scenario would be a final adoption of the new Regulation by the end of 2016.

7. Update on US aquaculture standards

US informed that the adoption of aquaculture standards has been postponedslowed but still plan to have a proposal out later in 2016.

8. AOB

OFIS irregularities: EC called US attention again to the delays in replying US responses to OFIS irregularities' notifications. US is the country with the worst record in replying late. This is public information shared with EU Member States and could damage US image. US expressed its willingness to discussimprove the situation. US subsequently met via teleconference with EU on February 22, 2016, to clarify EU expectations regarding irregularity closure, especially given the complexity and age of many of the EU irregularity findings. This meeting has resulted in significant progress in irregularity resolution by the US.

Next meeting: March-April 2016

Manuel ROSSI PRIETO

From: Valeriya StaykovaTo: Gebault King, ReneeA - AMSCc: Courtney, Cheri - AMS; Benoit DubeSubject: Re: 29 April draft minutes US-CFIADate: Thursday, June 02, 2016 9:30:13 AMAttachments: CFIA ACIA - #8203212 - v1 - 2016 APR 29 US CAN dvc minutes.DOCX

Dear Renée, Thank you for drafting the minutes and for the opportunity to comment. We have includedour edits for your consideration in the attached copy of the minutes. Regards,Valeriya

Valeriya StaykovaLead Auditor /Chef-auditeurLabelling, Organic Regime and Packaging/Étiquetage, Le Régime Bio et EmballageConsumer Protection and Market Fairness | Division de la protection des consommateurs et de l'équité desmarchésCanadian Food Inspection Agency | Agence canadienne d'inspection des aliments 1400 Merivale Road, Tower 2Floor 6, Room 252Ottawa, Ontario K1A 0Y9Tel: (613) 773-6222, Fax 613-773 - [email protected]

>>> "Gebault King, ReneeA - AMS" <[email protected]> 2016-05-16 1:26 PM >>>Dear Valeriya, Please find attached the draft minutes from our recent teleconference held on 29 April 2016. I wouldappreciate it if you and your team could review these draft minutes and provide any edits in “trackchanges” mode. Kind regards,

Renée



(b) (6)

This electronic message contains information generated by the USDA solely for the intended recipients. Anyunauthorized interception of this message or the use or disclosure of the information it contains may violate thelaw and subject the violator to civil or criminal penalties. If you believe you have received this message in error,please notify the sender and delete the email immediately.

Canada – U.S. Technical Working Group

April 29, 2016 – by Teleconference

Time/Location:

1:30-3:00 pm. Washington D.C., USA

• Room 409, USTR, 1724 F St. NW • IP Address: 65.207.24.228 • Telephone in room: 202.395.6077

1:30 p.m. – 3:00 p.m. Ottawa, CAN

Cisco IP based Videoconferencing system DIAL OR @video.gc.ca OR @

Polycom IP based Videoconferencing system DIAL OR ## OR video.gc.ca##

ISDN based Videoconferencing system DIAL Enter “#” when prompted.

By Telephone OR

Enter “#” when prompted.

Purpose:

Ongoing discussions for maintenance of the equivalence agreement between the U.S. and Canada.

Agenda

1. Welcome and Introductions a. Connected via teleconference.

2. Review June 10, 2015 meeting minutes

a. Compliance issues i. Bob Thomas: CFIA sent information to USDA NOP; CFIA received letter

from the USDA NOP; issue is resolved. ii. Natural Health Products: this issue is under the authority of Health

Canada; USDA NOP has not yet been contacted by Health Canada.

(b) (6)

(b) (6)(b) (6) (b) (6)

(b) (6)

(b) (6)(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)

iii. ACTION: CFIA will share the pertinent Health Canada contact information with USDA NOP.

b. CFIA sent to USDA NOP 18 positive pesticide residue sampling results. The NOP treats these requests for follow-up from the CFIA as complaints (15 deferred; 2 closed; 1 ongoing)

i. Another branch program, the National Chemical Residues Monitoring Program, within the CFIA (independent of the organic program) performs manages the sampling/testing for the CFIA organic program., but The CFIA’s organic program acknowledges that there are issues with timeliness of notices and accuracy completeness of sample information. have occurred.

ii. The CFIA organic program staff may re-evaluate this process and focus on using a risk assessment approach; USDA NOP would be interested in reviewing the CFIA proposed directive.

c. Re-assessment (refer to item #4) i. CFIA provided updated standards and a summary of the key changes side

by side ii. US conducting our own side-by-side analysis and a desk audit

d. Role of “observer” clarification (refer to #6 Plurilateral) e. NOP provided update on Mexico

3. Annual Reports

a. Annual reports shared b. NOP: no questions at this time c. CFIA: follow-up questions

i. Sampling and testing: NOP explained policy on mandatory sampling (require 5% minimum per 2013 requirement); NOP conducted training and published instructions for certifiers.

ii. Requested clarification on the list of ACAs posted on website 1. “Certifiers active by country” list per the ACA 1) statement of

geographical activity (self-report, from audit, or by request), 2) by US state, or 3) alphabetically.

4. Re-assessment of U.S.-Canada Organic Equivalency Arrangement (USCOEA)

a. Proposed timeline: i. The side-by-side analysis and desk audit process will continue into May

and the summer 2016: ii. ACTION: Within two weeks, CFIA will send a table to NOP that contains

the COR standards for NOP to use as part of the desk audit (standards comparison)

iii. September : Post-desk audit review and discussion via videoconference iv. Spring 2017: On-site assessment of each program v. Summer 2017: Finalize terms of the USCOEA

b. Organic import certificates status update i. USDA and CFIA agreed last year to change the attestation to an import

certificate requirement ii. USDA is developing a proposed rule to require import certificates for all

product entering the U.S. (not just for equivalence arrangements) iii. CFIA still exploring options; trying to use an existing form if possible; the

organic import certificate proposal is a priority for this fiscal year. iv. Address this item again during equivalency renewal.

5. USCOEA questions

a. COR CB accreditation in Third Country (“Country A” trade scenario) b. Trade route is based on the competent authority to ensure it meets the terms of the

specific arrangement

6. USDA updates a. Organic Livestock and Poultry Practices (OLPP):

i. NOP published proposed rule on April 15; comment period open to domestic and international comment until June 13; the timeline to review all comments and finalize the rule is not specific.

ii. Address this further during equivalency renewal iii. ACTION: NOP to share web link about OLPP release with CFIA

b. Hydroponics i. The NOSB Hydroponic and Aquaponic Task Force is currently working

on this issue. ii. Task force report to the NOSB will be completed in June; NOP expects

proposals at the November 2016 NOSB meeting. iii. ACTION: NOP share link to report when available on NOP website iv. Address this item again during equivalency renewal.

c. Aquaculture i. NOP plans to have a proposed rule by summer 2016, which will go out for

public comment, after which a final regulation is the goal; the proposed rule essentially reflects the NOSB recommendations.

ii. Address this item during equivalency renewal because it is not currently part of the arrangement.

iii. Aquaculture products are not under the scope of the current Organic Products Regulations in Canada.

d. Pet Food

i. NOP plans to have a proposed rule by summer 2016, which will go out for public comment, after which a final regulation is the goal; the proposed rule essentially reflects the NOSB recommendations.

ii. CFIA reminded the USDA NOP that this scope is not within COR mandate

e. Apiculture i. NOP plans to have a proposed rule by summer 2016, which will go out for


7. CFIA updates a. Sr. management changes at CFIA:

i. New Executive Director, Food Import/Export and Consumer Protection Directorate: Lyzette Lamondin

i.ii. New National ManagerDirector, Strategies & PlanningConsumer Protection and Market Fairness Division: Kathy Twardek

ii.iii. New Program Specialist, Labeling, Organic & Packaging: David Ladd b. New Canadian Organic Standards (COS) released November 25, 2015 c. Reviewing comments currently and expecting the Safe Food for Canadians

rRegulations to go to out pre-publication for public comment in Canada Gazette, Part I in late 2016.

i. Anticipating that aquaculture will come be included into the scope of the organic part of the regulations

ii. No changes expected for renegotiations of equivalencies d. CFIA attended BioFach and presented a session on plurilateral/multilateral

arrangements

8. Organic Materials Review Institute (OMRI) and ISO 17065 Accreditation a. USDA NOP discussed material review programs and their roles under the USDA

organic program. NOP met with OMRI during NOSB meetings this week: OMRI discussed that they provide material review services in Canada (per “Input Verification under COR” memo from CFIA). USDA wants to confirm that OMRI ISO 17065 accreditation by USDA AMS is accepted (per CFIA memo). USDA AMS has granted ISO 17065 accreditation to OMRI for the scope of the National Organic Program and CAN/CGSB 32.311 Input Product Review.

b. CFIA confirmed that OMRI may be used by Canadian CBs for material review as an accepted third party (per CFIA memo requirement #3); CFIA will evaluate this situation further.

c. USDA and CFIA agreed that the responsibility for material approval still lies ultimately with the CB.

9. Plurilateral trade arrangements

a. U.S. and EU have developed a non-paper on the plurilateral concept that contains broad ideas and to foster further discussions. The group is also working closely with Switzerland (CH).

b. CH is organizing the first government to government meeting (planned for November 2016 in CH). CAN will be formally invited by U.S. to participate in this meeting (after clearance of non-paper is complete).

c. ACTION: USDA will 1) share the non-paper with CFIA and 2) set up a call to review the non-paper with CFIA (tentatively planned for June).

10. USDA update on Mexico a. Onsite assessment is completed and was favorable. b. Working to further develop the arrangement structure over the summer 2016. c. New program has several items to address but USDA is optimistic for establishing

equivalency before April 2017.

11. CFIA Updates a. Mexico: CFIA negotiations are in-process and are expected to move forward after

Mexico concludes negotiations with the EU and U.S. b. S. Korea: negotiations with CFIA are in process; S. Korea and the has assessed

CFIA have assessed each other’s system; now negotiating terms of the arrangement.

c. EU: The EU-CAN equivalency with EU CAN was renewedexpanded; it now includes organic wine and Canadian multi-ingredient products containing imported ingredients.

d. CFIA is currently working to extend the equivalency with CH currentlysimilarly as with the EU

12. ETKO (Turkey)

a. An additional assessment was conducted by CFIA and a decision will be rendered soon.

b. USDA has no plans to conduct an onsite assessment currently due to U.S. travel restrictions for Turkey.

c. ACTION: CFIA will inform the USDA NOP of the decision rendered for ETKO.

13. Next Technical Working Group meeting a. Tentatively planned for October 2016

Canada – U.S. Organic Equivalence Discussions


Participants

Canada Rola Yehia National Manager Canadian Food Inspection Agency (CFIA) Valeriya Staykova Lead Auditor Canadian Food Inspection Agency (CFIA) Benoit DubeDubé Regulations and Standards Officer Canadian Food Inspection Agency (CFIA) U.S. Department of Agriculture Miles McEvoy Deputy Administrator National Organic Program (NOP) Agricultural Marketing Service (AMS) Cheri Courtney Director, Accreditation and International Activities Division National Organic Program (NOP) Agricultural Marketing Service (AMS) Renée Gebault King Accreditation Manager National Organic Program (NOP) Agricultural Marketing Service (AMS) Kelly Strzelecki Senior Trade Advisor, Processed Products & Technical Regulations Division Foreign Agriculture Service (FAS)

Office of the U.S. Trade Representative Julia Doherty Senior Director, SPS and Agricultural Affairs Office of the U.S. Trade Representative (USTR) Executive Office of the President

From: McEvoy, Miles - AMSTo: Gebault King, ReneeA - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: RE: Canada meeting, draft minutesDate: Thursday, May 05, 2016 1:49:24 PMAttachments: 2016 Apr 29 US CAN dvc draft minutes-mvm.docx

Thanks Renee!Redline edits attached.Miles

From: Gebault King, ReneeA - AMS Sent: Monday, May 02, 2016 1:26 PMTo: McEvoy, Miles - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Strzelecki, Kelly - FAS <[email protected]>; Doherty,Julia <[email protected]>Subject: Canada meeting, draft minutes Hi, Team! Attached are the draft minutes from last Friday’s teleconference with Canada. I would appreciate it ifyou could review these minutes and provide feedback (track changes mode). I would like to send the minutes to Canada by the end of the week if possible. Thanks!

Renée GK

USDA NOPOffice: 202.690.1312 | Mobile: [email protected]

(b) (6)

i. USDA and CFIA agreed last year to change the attestation to an import certificate requirement

ii. USDA is developing a proposed rule to require import certificates for all product entering the U.S. (not just for equivalence arrangements)

iii. CFIA still exploring options; trying to use an existing form if possible; the organic import certificate proposal is a priority for this fiscal year.

iv. Address this item again during equivalency renewal.

5. USCOEA questions a. COR CB accreditation in Third Country (“Country A” trade scenario) b. Trade route is based on the competent authority to ensure it meets the terms of the






on this issue. ii. T task force report to the NOSB will be completed in June; NOP expects





iii. d. Pet Food








Mexico concludes negotiations with the EU and U.S.

b. S. Korea: negotiations with CFIA are in process; S. Korea has assessed CFIA system; now negotiating terms of the arrangement.

c. EU: The equivalency with EU-CAN was renewed; it now includes organic wine

and multi-ingredient products.

d. CFIA is working to extend equivalency with CH currently

12. ETKO (Turkey) a. An additional assessment was conducted by CFIA and a decision will be rendered

soon. b. USDA has no plans to conduct an onsite assessment currently due to U.S. travel

restrictions for Turkey. c. ACTION: CFIA will inform the USDA NOP of the decision rendered for ETKO.

13. Next Technical Working Group meeting

a. Tentatively planned for October 2016



Participants

Canada Rola Yehia National Manager Canadian Food Inspection Agency (CFIA) Valeriya Staykova Lead Auditor Canadian Food Inspection Agency (CFIA) Benoit Dube Regulations and Standards Officer Canadian Food Inspection Agency (CFIA) U.S. Department of Agriculture Miles McEvoy Deputy Administrator National Organic Program (NOP) Agricultural Marketing Service (AMS) Cheri Courtney Director, Accreditation and International Activities Division National Organic Program (NOP) Agricultural Marketing Service (AMS) Renée Gebault King Accreditation Manager National Organic Program (NOP) Agricultural Marketing Service (AMS) Kelly Strzelecki Senior Trade Advisor, Processed Products & Technical Regulations Division Foreign Agriculture Service (FAS)


From: Gebault King, ReneeA - AMSTo: Howley, JannaB - AMSSubject: RE: ETKODate: Tuesday, June 30, 2015 3:28:00 PMAttachments: image001.png

image002.png

Wahoo! J

From: Howley, JannaB - AMS Sent: Tuesday, June 30, 2015 3:28 PMTo: Gebault King, ReneeA - AMSSubject: RE: ETKOThank you! This is perfect.

From: Gebault King, ReneeA - AMS Sent: Tuesday, June 30, 2015 10:48 AMTo: Howley, JannaB - AMSSubject: FW: ETKOImportance: HighFYI

From: Sent: Tuesday, June 30, 2015 10:36 AMTo: Gebault King, ReneeA - AMSCc: ; Courtney, Cheri - AMSSubject: RE: ETKODear Renée,In terms of nonconformities, relevant information was primarily sourced from the IOAS audit report.In summary the assessors found the ETKO control system deficient in its implementation in anumber of important aspects including:• Insufficient rigour and integrity of inspection• Acceptance of vague authority declarations on previous land use without checking veracity• Inability to demonstrate effective controls• Poor management of sample taking• Inattention to dates of last use of non‐allowed inputs and parallel production• Lack of on‐site input/output balance audits at handlers and processors• Lack of regulation of non‐organic seed use• Not holding the operator to account for failings by sub‐contractors• Sales by sub‐contractors• An inspector payment system in Ukraine that lends itself to conflicting interestWith specific regard to the irregularity cases notified in OFIS, the assessors found that the ETKOinvestigation was unable to demonstrate full traceability of the product or fully link available samplesand analyses to the shipments. More details can be made available where necessary.These nonconformities together with the recurrence of irregularity cases notified in OFIS indicated asystematic malfunctioning of the control measures applied. It also appeared that ETKO was unableto take adequate corrective measures in respect of the deficiencies reported and in response to theserious infringements observed. In such circumstances the risk existed for the consumer to bemisled about the true nature of the products certified by ETKO. Consequently, ETKO was withdrawnfrom the EU list.Best regards,

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(

From: Gebault King, ReneeA - AMS [mailto:[email protected]] Sent: Friday, June 26, 2015 3:45 PMTo: Subject: FW: ETKODear I hope this e‐mail finds you well. The USDA NOP is in need of additional informationregarding ETKO. I would appreciate it if the EU could share information on the specificnonconformities and other deficiencies noted with respect to ETKO.Kind regards,

RenéeRenée Gebault King, Ph.D.Accreditation ManagerOffice: 202.690.1312 | Mobile: [email protected] National Organic Program | 1400 Independence Ave SW | Room 2649‐South, Stop 0268Washington, D.C. 20250‐0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e‐mail!

From: Gebault King, ReneeA - AMS Sent: Friday, June 19, 2015 1:59 PMTo: Cc: Courtney, Cheri - AMS; ;

Subject: RE: ETKODear ,Thank you for providing information on the actions the EU has taken with regard to EkolojikTarim Kontrol Organizasyonu (ETKO).The USDA NOP is currently in the process of gathering information on the situation withETKO. To this end, the USDA NOP would appreciate if the EU could share information on thespecific nonconformities and other deficiencies noted with respect to ETKO.Kind regards,

Renée

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(b) (6)

(b) (6), (b) (7)(C)(b) (6)

(b) (6), (b) (7)(C)

(b) (6)

From: Lopez, JasonJ - AMSTo: Gebault King, ReneeA - AMSSubject: RE: Fed Ex Package to UkraineDate: Tuesday, September 08, 2015 7:56:09 AM

It’s not bad but a little tougher when you come in in the 9th inning J

Jason LopezAccreditation ManagerUSDA National Organic Program1400 Independence Ave, SWRoom 2649- South, Stop 0268Washington, DC 20250-0268Office: (202)260-9445www.ams.usda.gov/nop

From: Gebault King, ReneeA - AMS Sent: Tuesday, September 08, 2015 7:55 AMTo: Lopez, JasonJ - AMSSubject: RE: Fed Ex Package to UkraineDon’t you just love being a detective?! JFYI: I noted that Kherson as referenced in the recent complaint against ETKO, so there may be anopportunity to find out the correct phone number through those channels instead. I couldn’t findanything via a search on the ol’ interwebs…RGK

From: Lopez, JasonJ - AMS Sent: Tuesday, September 08, 2015 7:53 AMTo: Gebault King, ReneeA - AMSSubject: RE: Fed Ex Package to UkraineOK I’ll see what I can find to track something down.Thanks


From: Gebault King, ReneeA - AMS Sent: Tuesday, September 08, 2015 7:51 AMTo: Lopez, JasonJ - AMSSubject: RE: Fed Ex Package to UkraineGood morning, Jason!Yep, the Ukraine outfit is De Trade House Kherson. I have the original receipts in the file on my desk(they should be right at the front and are one-page printouts with bar codes). The other letter wasfor Ivolga Holding in Kazakhstan, but no word back on that yet as undeliverable. FYI: I’ve tried thephone number listed for Trade House Kherson and all it does it ring, ring, ring…no voicemail, noanswer.RGK

From: Lopez, JasonJ - AMS

Sent: Tuesday, September 08, 2015 7:44 AMTo: Gebault King, ReneeA - AMSSubject: RE: Fed Ex Package to UkraineGood Morning Renee,Is this letter is the one sent to De Trade House Kherson in the Ukraine sent 6-25-15? Joan said it wassent a few days ago???


From: Gebault King, ReneeA - AMS Sent: Friday, September 04, 2015 3:12 PMTo: Lopez, JasonJ - AMSCc: Mann, Renee - AMSSubject: FW: Fed Ex Package to UkraineFYI: Jason,

From: Avila, Joan - AMS Sent: Friday, September 04, 2015 8:22 AMTo: Gebault King, ReneeA - AMSSubject: Fed Ex Package to UkraineRenee:I got a message from Fed Ex regarding your package to the Ukraine that I sent a few days ago. Fed Exsays that the address is incorrect and there is no valid contact information. Can you provide themwith the recipient’s cell phone number or email address? Please call Fed Ex at 1-800-247-4747. Ifyou can’t provide a new address or other means of reaching the recipient, you can ask Fed Ex todestroy the letter or ship it back to you at our expense. The tracking number for this shipment is774350539751.Thanks.Joan F. Avila, SecretaryUSDA, Agricultural Marketing ServiceNational Organic ProgramStop 0268, Room 2642-S1400 Independence Avenue, SW.Washington, D.C. 20250-0268(202) [email protected]

(b) (5)

From: Lopez, JasonJ - AMSTo: Gebault King, ReneeA - AMSSubject: RE: Fed Ex Package to UkraineDate: Tuesday, September 08, 2015 7:58:43 AM

Do we know what commodities they traded?


From: Gebault King, ReneeA - AMS Sent: Tuesday, September 08, 2015 7:55 AMTo: Lopez, JasonJ - AMSSubject: RE: Fed Ex Package to UkraineDon’t you just love being a detective?! JFYI: I noted that Kherson as referenced in the recent complaint against ETKO, so there may be anopportunity to find out the correct phone number through those channels instead. I couldn’t findanything via a search on the ol’ interwebs…RGK

From: Lopez, JasonJ - AMS Sent: Tuesday, September 08, 2015 7:53 AMTo: Gebault King, ReneeA - AMSSubject: RE: Fed Ex Package to UkraineOK I’ll see what I can find to track something down.Thanks


From: Gebault King, ReneeA - AMS Sent: Tuesday, September 08, 2015 7:51 AMTo: Lopez, JasonJ - AMSSubject: RE: Fed Ex Package to UkraineGood morning, Jason!Yep, the Ukraine outfit is De Trade House Kherson. I have the original receipts in the file on my desk(they should be right at the front and are one-page printouts with bar codes). The other letter wasfor Ivolga Holding in Kazakhstan, but no word back on that yet as undeliverable. FYI: I’ve tried thephone number listed for Trade House Kherson and all it does it ring, ring, ring…no voicemail, noanswer.RGK

From: Lopez, JasonJ - AMS

Sent: Tuesday, September 08, 2015 7:44 AMTo: Gebault King, ReneeA - AMSSubject: RE: Fed Ex Package to UkraineGood Morning Renee,Is this letter is the one sent to De Trade House Kherson in the Ukraine sent 6-25-15? Joan said it wassent a few days ago???


From: Gebault King, ReneeA - AMS Sent: Friday, September 04, 2015 3:12 PMTo: Lopez, JasonJ - AMSCc: Mann, Renee - AMSSubject: FW: Fed Ex Package to UkraineFYI: Jason,

From: Avila, Joan - AMS Sent: Friday, September 04, 2015 8:22 AMTo: Gebault King, ReneeA - AMSSubject: Fed Ex Package to UkraineRenee:I got a message from Fed Ex regarding your package to the Ukraine that I sent a few days ago. Fed Exsays that the address is incorrect and there is no valid contact information. Can you provide themwith the recipient’s cell phone number or email address? Please call Fed Ex at 1-800-247-4747. Ifyou can’t provide a new address or other means of reaching the recipient, you can ask Fed Ex todestroy the letter or ship it back to you at our expense. The tracking number for this shipment is774350539751.Thanks.Joan F. Avila, SecretaryUSDA, Agricultural Marketing ServiceNational Organic ProgramStop 0268, Room 2642-S1400 Independence Avenue, SW.Washington, D.C. 20250-0268(202) [email protected]

(b) (5)

From: Gebault King, ReneeA - AMSTo: "Valeriya Staykova"Cc: Courtney, Cheri - AMS; McEvoy, Miles - AMS; Benoit Dube; Gary LittleSubject: RE: Follow- up - RE: 29 April draft minutes US-CFIADate: Friday, July 01, 2016 12:37:00 PMAttachments: 2016 Apr 29 US CAN dvc minutes FINAL.docx

Dear Valeriya, After several weeks out of the office, I have returned and able to provide you with the final minutesfrom our teleconference (see attached). In a separate e-mail sent today, you should have received the invitation to participate in theplurilateral workshop and draft nonpaper for your review. We look forward to your feedback on the plurilateral nonpaper. I will be in touch in the next fewweeks to discuss plans to meet via videoconference or teleconference to discuss the nonpaper. In the meantime, please contact me if you have questions. Kind regards,

Renée



From: Valeriya Staykova [mailto:[email protected]] Sent: Wednesday, June 29, 2016 11:30 AMTo: Gebault King, ReneeA - AMS <[email protected]>Cc: Courtney, Cheri - AMS <[email protected]>; McEvoy, Miles - AMS<[email protected]>; Benoit Dube <[email protected]>; Gary Little<[email protected]>Subject: Follow- up - RE: 29 April draft minutes US-CFIA Hello Renée, I hope you are doing well. Could you please advise when we should expect to have the minutesfrom the US- Canada WG conference call finalized.

(b) (6)

Also, we discussed that NOP will share the non-paper on the plurilateral concept with CFIA inJune and we will set up a call to review it. We have not received a copy of the paper yet. I hopeyou will send the paper for our review shortly. Regards,Vaeriya

Valeriya StaykovaLead Auditor /Chef-auditeurForeign Country Assessments/Évaluation des pays étrangersCanadian Food Inspection Agency | Agence canadienne d'inspection des aliments 1400 Merivale Road, Tower 2Floor 6, Room 252Ottawa, Ontario K1A 0Y9Tel: (613) 773-6222, Fax 613-773 - [email protected]

>>> "Gebault King, ReneeA - AMS" <[email protected]> 2016-06-02 9:43 AM >>>Dear Valeriya, Thank you for providing feedback on the minutes. We will review them soon, but it may take a fewweeks to respond to you with a final version as several key staff are traveling or on vacation thismonth. Kind regards,

Renée



(b) (6)

From: Valeriya Staykova [mailto:[email protected]] Sent: Thursday, June 02, 2016 9:30 AMTo: Gebault King, ReneeA - AMS <[email protected]>Cc: Courtney, Cheri - AMS <[email protected]>; Benoit Dube<[email protected]>Subject: Re: 29 April draft minutes US-CFIA Dear Renée, Thank you for drafting the minutes and for the opportunity to comment. We have includedour edits for your consideration in the attached copy of the minutes. Regards,Valeriya

Valeriya StaykovaLead Auditor /Chef-auditeurLabelling, Organic Regime and Packaging/Étiquetage, Le Régime Bio et EmballageConsumer Protection and Market Fairness | Division de la protection des consommateurs et de l'équité desmarchésCanadian Food Inspection Agency | Agence canadienne d'inspection des aliments 1400 Merivale Road, Tower 2Floor 6, Room 252Ottawa, Ontario K1A 0Y9Tel: (613) 773-6222, Fax 613-773 - [email protected]

>>> "Gebault King, ReneeA - AMS" <[email protected]> 2016-05-16 1:26 PM >>>Dear Valeriya, Please find attached the draft minutes from our recent teleconference held on 29 April 2016. I wouldappreciate it if you and your team could review these draft minutes and provide any edits in “trackchanges” mode. Kind regards,

Renée


Office: 202.690.1312 | Mobile: [email protected] USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South, Stop 0268

(b) (6)

Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

This electronic message contains information generated by the USDA solely for the intended recipients. Anyunauthorized interception of this message or the use or disclosure of the information it contains may violate thelaw and subject the violator to civil or criminal penalties. If you believe you have received this message in error,please notify the sender and delete the email immediately.



Time/Location:



1:30 p.m. – 3:00 p.m. Ottawa, CAN


Polycom IP based Videoconferencing system DIAL OR ##OR video.gc.ca##


By Telephone OR


Purpose:


Agenda


2. Review June 10, 2015 meeting minutes a. Compliance issues

i. Bob Thomas: CFIA sent information to USDA NOP; CFIA received letter from the USDA NOP; issue is resolved.

ii. Natural Health Products: this issue is under the authority of Health Canada; USDA NOP has not yet been contacted by Health Canada.

(b) (6)

(b) (6) (b) (6)(b) (6)

(b) (6)(b) (6)

(b) (6)(b) (6)

(b) (6)

(b) (6)


b. CFIA sent to USDA NOP 18 complaints (15 deferred; 2 closed; 1 ongoing) i. Another branch in CFIA (independent of the organic program) performs

the sampling/testing for the CFIA organic program, but issues with timeliness of notices and accuracy of sample information have occurred.

ii. CFIA organic program staff may re-evaluate this process and focus on using a risk assessment approach; USDA NOP would be interested in reviewing the CFIA proposed directive.

c. Re-assessment (refer to item #4) i. CFIA provided updated standards and side-by-side

ii. US conducting our own side-by-side analysis and a desk audit d. Role of “observer” clarification (refer to #6 Plurilateral) e. NOP provided update on Mexico

3. Annual Reports









iii. September : Post-desk audit review and discussion via videoconference iv. Spring 2017: Onsite assessment of each program v. Summer 2017: Finalize terms of the USCOEA


certificate requirement















iii. d. Pet Food



e. Apiculture



i. New National Manager, Strategies & Planning: Kathy Twardek ii. New Program Specialist, Labeling, Organic & Packaging: David Ladd

b. New Canadian Organic Standards (COS) released November 25, 2015 i. Reviewing comments currently and expecting regulations to go out for

public comment in Canada Gazette. ii. Anticipating that aquaculture will come into scope

iii. No changes expected for renegotiations of equivalencies c. CFIA attended BioFach and presented a session on plurilateral/multilateral

arrangements



b. CFIA confirmed that OMRI may be used by Canadian CBs for material review as an accepted third party (per CFIA memo requirement #3), CFIA will evaluate this situation further.






10. USDA update on Mexico

a. Onsite assessment is completed and was favorable. b. Working to further develop the arrangement structure over the summer 2016. c. New program has several items to address but USDA is optimistic for establishing















Participants



From: McEvoy, Miles - AMSTo: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMSSubject: RE: MOA debriefDate: Thursday, January 26, 2017 11:01:10 AM

Thanks for the readout. Sounds like it went well. Thanks for representing us so well. Safe travels back.Miles

-----Original Message-----From: Tucker, Jennifer - AMSSent: Thursday, January 26, 2017 10:37 AMTo: McEvoy, Miles - AMS <[email protected]>; Gebault King, ReneeA - AMS<[email protected]>Subject: MOA debrief

Very quick debrief from presentation – it appears to have gone well. I got questions about administration transition,OLPP, the certified transition program, and a very pointed question about ETKO. I used the points that we had sentto Wall Street Journal on the latter topic, shared the current status of the transitional program – only what is public,and ended up using all the transition talking points. They seemed to work well in that there were no follow ups.

People seem genuinely concerned about what will happen with the program in the next few months and alsosurprised by how small the program actually is – using the 1 billion US sales for every staff member metric reallydrives that point home.

No one self identified as press. There were about 100 people in the audience – Sue said attendance was very lowthis year.

I'll be going to a couple of sessions and then getting on a plane this afternoon. Just wanted to give you a quick readout in case there were any questions from the home team.

Jenny

From: Wilburn, Tammie - AMSTo: McEvoy, Miles - AMS; Mann, Renee - AMS; Regalado, Andrew - AMSCc: Courtney, Cheri - AMS; Tucker, Jennifer - AMS; Holmes, Vella - AMS; Michael, Matthew - AMS; Gebault King,

ReneeA - AMSSubject: RE: Organic corn importsDate: Monday, November 07, 2016 2:10:11 PMAttachments: Certified Organic Corn Operations per Certifiers.xlsx

Hi Miles,

I am still waiting on information and/or clarification from several certifiers. I am attaching information submitted todate, but based on the data submitted by Andrew,

The operations under certification are: 1. Field Farms(ProCert), 2. Mosher Products (OneCert), 3. Tiryaki Agro Gida (IMO), and 4. Caprock (CCOF).

. Thesecompanies are under APHIS' purview per IMO data, since they have imported from prohibited countries. APHIS isready to assist us in visiting these operations to confirm source and possibly collect samples.

If you're ok with this I will draft the four letters for your signature tomorrow or Wednesday. Renee & Vella perhapswe can set up a call with APHIS this week to discuss next steps.

Tammie

-----Original Message-----From: McEvoy, Miles - AMSSent: Friday, November 04, 2016 8:22 PMTo: Mann, Renee - AMS; Wilburn, Tammie - AMSCc: Courtney, Cheri - AMS; Tucker, Jennifer - AMS; Holmes, Vella - AMS; Michael, Matthew - AMS; GebaultKing, ReneeA - AMSSubject: Organic corn imports

During my meetings with European officials this past week I learned about continued concerns regarding organicfeed production in Eastern Europe. The European Union requires Certifiers to conduct residue testing on importedorganic feed. I'd like to send letters to Certifiers that are certifying Eastern European organic grain that they mustconduct residue testing under the authority of 205.501(a)(21). I will explain in more detail on Monday.

Tammie - Please provide a list of Certifiers, certified operations, and traders involved in the organic grain trade inEastern Europe by COB Monday. I understand that you may not have a complete list but it will be a place to start.

Renee - Please draft the certifier letters. I'll meet with you on Monday morning to explain in more detail. Thanks.

Miles V McEvoyDeputy AdministratorUSDA National Organic Program

(b) (5)

(b) (5)

Certifying Agent Crops Handling Grower GroupControl Union No YesBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes No NoBioInspecta AG*BCS Öko-Garantie GmbH Yes Yes YesBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes Yes YesBCS Öko-Garantie GmbH No Yes No

BCS Öko-Garantie GmbH Yes Yes NoControl Union No YesControl Union No YesControl Union No YesControl Union Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes Yes NoControl Union No Yes NoControl Union No Yes NoBCS Öko-Garantie GmbH Yes No YesBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes Yes YesBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH Yes No NoBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH No Yes NoBioInspecta AG*BioInspecta AG*BioInspecta AG*Control Union Yes YesControl Union Yes YesControl Union Yes YesControl Union No YesControl Union No YesControl Union No YesBCS Öko-Garantie GmbH No Yes NoBCS Öko-Garantie GmbH Yes Yes No

IBD - nothing to reportEtkoEcoCertLACONACOIMO

Operation's Name Country U.S. Based CustomerAGROPEX BULGARIA LTD BulgariaSociedad Agrícola Winter Seed Ltda. ChileAgrícola Las Bandurrias Ltda ChileSociedad Agrícola Winter Seed Ltda. ChileTai'an Taishan Asia Food Co., Ltd. ChinaXinjiang Good Harvest Agriculture ChinaDalian Shengfang Organic Food Co., Ltd. ChinaSunshine (Tianjin) Produce Ltd. ChinaLinyi Wonderful Foodstuff Co., Ltd. ChinaLiaoning Zhenlong Native Produce Holding Co., Ltd. ChinaSunshine (Tianjin) Produce Ltd. ChinaYongshan Tianshan Food Co., Ltd. ChinaHeilongjiang Land Reclamation Dragon King ChinaLiaoning Zhenlong Native Produce Holding Co., Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaKaize Group Limited ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaDalian Xinglongken Organic Products Co., Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaLiaoning Zhenlong Native Produce Holding Co., Ltd. ChinaDunhua Dewei Organic Products Co., Ltd. ChinaKaize Group Limited ChinaSunshine (Tianjin) Produce Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaDalian Shengfang Organic Food Co., Ltd. ChinaZunyi County Taida Cereal & Oil Co., Ltd. ChinaHeilongjiang Jiansanjiang Lvnong ChinaQingdao Foodlink Co., Ltd. ChinaLijiang Daran Biology Co., Ltd. ChinaKaize Group Limited ChinaLiaoning Zhenlong Native Produce Holding Co., Ltd. ChinaSunshine (Tianjin) Produce Ltd. ChinaDalian Spring Agricultural Products Co., Ltd. ChinaDalian Sun Found International Trading Co., Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaLinyi Dongxu Foods Co., Ltd. ChinaDalian Xinglongken Organic Products Co., Ltd. ChinaDalian Xinglongken Organic Cereal & Oil Co., Ltd. ChinaHakan Dubai Agribusiness Agrícola Compañía Limitada Ecopallana EcuadorIndustrias Alen Eveliza EcuadorPerla Negra La Loma S.C.P EcuadorSumak Mikuy S.C.C. EcuadorCAMARI Sistema Solidario Ecuador

Agripure Egypt EG AegyptenTeshome Anteneh Alemneh Imp. Exp. EthiophiaSELAMAWIT G/MARIAM EthiophiaTOO ORIENT TRADE CO.LTD KazakhstanAkasya Tarim Urunleri Gida San. ve Tic A.S. KyrgyszstanJosé Leobardo Ravelero Cruz MexicoEl Sauz Vega, SPR de RL de CV MéxicoMexarom, S. de R.L. de C.V. MéxicoDFI Organics Inc NetherlandsDoens Food Ingredients B.V NetherlandsCooperativa Agraria Bio – Orgánica PeruUHTCO Corporation PeruPeru Naturals Corporation S.A.C. PeruAYNI - ESCUELA DE NUTRICIÓN HOLÍSTICA PerúANDINOINDUSTRIAS S.A.C. PerúVILLA ANDINA S.A.C. PerúAYMARA PERU S.A.C. PerúGreen Garden Agricultural and Animal Husbandry Ltd RussiaAGRO MICHYRINA RussiaBri-wester Trading Co., Ltd. RussiaRus Agro Export Ltd RussiaIsik Tarim Ürünleri San. ve Tic. A.S. TurkeyIsik Tarim Ürünleri San. ve Tic. A.S. TurkeyIsik Tarim Ürünleri San. ve Tic. A.S. TurkeyBeyaz Agro Ithalat Ihracat San. Ve TIC.A.S. TurkeyGZ TARIM ÜRÜNLERI TIC. LTD. STI. TurkeyBeyaz Turkey DFI OrganicsGZ Turkey Field FarmsEkoturka Turkey PerdueAkasya Tarim Urunleri Gida San. ve Tic A.S. TurkeyEko Turka Tekstil Tarim Hayvancilik Tasimacilik Sanayi TurkeyBURC EKOLOJIK TARIM TEKSTIL URUNLERI NAKLIYAT TurkeyYusufcan Tarim Ur.Gub.Ins.Nak.ve Zirai Ilac San TurkeyTILLO TARIM (IBRAHIM EKIN) TurkeyKadioglu Tarim Ticaret Ve Sanayi A.S. Turkey Hakan Organics DMCC Vereinigte Arab.Excalibur Investment LLC Vereinigte Arab.

Tiryaki

U.S. Customer Certifier Compliance Issues

BioInspecta

Per CUC, a request received for crosschecking the origin of a shipment related to D

Control UnionBCSControl Union

DFI Organics Inc.

From: [email protected]: Gebault King, ReneeA - AMSCc: [email protected]; Courtney, Cheri - AMS;

Subject: RE: OWG meeting minutesDate: Wednesday, May 25, 2016 5:32:38 AMAttachments: image001.png

image002.png160202 OWG minutes FINAL.doc

Thanks, Renée. All your comments are fine, including the improvement on US responses to OFIS irregularitiesnotifications. Situation is getting better since our teleconference. Keep going! You will find attached a clean version as agreed by both sides. Best regards Manuel ROSSI PRIETOPolicy Officer – International Sector

European CommissionDG Agriculture and Rural DevelopmentDirectorate B. Multilateral Relations, Quality PolicyUnit B.4. Organics

L130 06/100B-1049 Brussels/Belgium+32 2 295 21 [email protected]

From: Gebault King, ReneeA - AMS [mailto:[email protected]] Sent: Tuesday, May 24, 2016 2:38 PMTo: ROSSI PRIETO Manuel (AGRI)Cc: ONOFRE Joao (AGRI); Courtney, Cheri - AMS; Subject: OWG meeting minutes

(b) (6)(b) (6)

(b) (6)

Dear Manuel, Please accept my apologies for the delay in sending comments. Attached are the draftminutes from the 2 February meeting of the Organic Working Group. I appreciate your understanding. Kind regards,

Renée



This electronic message contains information generated by the USDA solely for theintended recipients. Any unauthorized interception of this message or the use ordisclosure of the information it contains may violate the law and subject the violator tocivil or criminal penalties. If you believe you have received this message in error,please notify the sender and delete the email immediately.

(b) (6)









February-April:





2


April-July


September-October










On Taiwan, US informed about a peer review that will take place in US in March. US peer review audit proposed for early-2017 in Taiwan. Discussions will continue as US aims to ensure products access to Taiwan, and residue test and hold procedures at border are revised. EC referred to alternative solutions as the recognition of Taiwan's control authority.


On Costa Rica, US confirmed interest in having equivalency recognition but there are significant concerns about Costa Rica’s lack of investigation and enforcement on fraudulent products.

3

5. Update on ETKO





US informed that the adoption of aquaculture standards has slowed but still plan to have a proposal out later in 2016.

8. AOB

OFIS irregularities: EC called attention to delays in US responses to OFIS irregularities' notifications. US expressed its willingness to discuss the situation. US subsequently met via teleconference with EU on February 22, 2016, to clarify EU expectations regarding irregularity closure, especially given the complexity and age of many of the EU irregularity findings. This meeting has resulted in significant progress in irregularity resolution by the US.


From: Strzelecki, Kelly - FASTo: Gebault King, ReneeA - AMS; Courtney, Cheri - AMSSubject: RE: QCS - Evidence of QCS Processing Activity in Ecuador (Email 1of 3)Date: Thursday, September 29, 2016 11:14:08 AM

Thanks Renee, I agree the first option seems the most efficient. Can we try that first, but also try toschedule a call for later in October? Cheers,Kelly Kelly StrzeleckiSenior Trade AdvisorProcessed Products & Technical Regulations DivisionOffice of Agreements and Scientific AffairsUSDA/Foreign Agricultural Service(202) 690-0522

From: Gebault King, ReneeA - AMS Sent: Thursday, September 29, 2016 10:54 AMTo: Strzelecki, Kelly - FAS; Courtney, Cheri - AMSSubject: RE: QCS - Evidence of QCS Processing Activity in Ecuador (Email 1of 3) Hi Kelly, I was not aware of this issue so thanks for bringing it to my attention. I know that annex revisionstake quite a bit of time (several weeks/months), so I can appreciate QCS’ need for the EU to provideinterim verification of their processing/handling status. It does seem like a fairly quick fix. Two options:

1)

2)

We haven’t met since 2 Feb. 2016 because the plurilateral workshop has garnered the lion’s share ofour EU interactions lately. Perhaps the time is right for another DVC? Based on the last meeting minutes, the agenda could include the following items:

· QCS listing error on EU Annex III· EU response to U.S. questions (I sent a question about olive oil to Manuel, but no response

yet)· Equivalency updates from both parties· Update on ETKO· Update on EU regulations (final adoption)· Update on U.S. aquaculture

(b) (5)

· Compliance updates· Remaining plurilateral prep for U.S. and EU projects

I prefer the first option, but would appreciate your thoughts.

Renée

From: Strzelecki, Kelly - FAS Sent: Thursday, September 29, 2016 10:32 AMTo: Gebault King, ReneeA - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>Subject: FW: QCS - Evidence of QCS Processing Activity in Ecuador (Email 1of 3) Hi Renee and Cheri,While at Expo East, Marty Mesh, QCS, approached me to chat about an issue with their EU status asa recognized certifier. We also called Ramkrishnan to discuss. Apparently the EU doesn’t have QCSlisted for processing/handling in their Annex and there are now producers in Ecuador who arebasically suing QCS for false representation (or something like that). Apparently Ram has been intouch with the EU, I believe Manuel, and they have said they will change the listing for QCS whenthey make the next revision to their annex. In the mean time, QCS is still having problems and wouldlike the EU to write a letter that QCS could share with clients saying that there has been a clericalerror in the way they are listed. I’m not sure if QCS has brought this to your attention, but it seems like a fairly simple fix if we canget the EU’s support. Attached and below are more information on this. Let me know what you think. Cheers,Kelly Kelly StrzeleckiSenior Trade AdvisorProcessed Products & Technical Regulations DivisionOffice of Agreements and Scientific AffairsUSDA/Foreign Agricultural Service(202) 690-0522

From: Ramkrishnan.P.B. [mailto:[email protected]] Sent: Monday, September 26, 2016 11:59 AMTo: Strzelecki, Kelly - FASSubject: FW: QCS - Evidence of QCS Processing Activity in Ecuador (Email 1of 3) Kelly, Can you please help. Do you also need other attachments from email 2 and email 3.

From: Krista Wanser [mailto:[email protected]] Sent: Thursday, September 22, 2016 10:02 PMTo: [email protected]; [email protected]: Ramkrishnan.P.B.; Beth Rota; Robin SchrieberSubject: QCS - Evidence of QCS Processing Activity in Ecuador (Email 1of 3) Manuel ROSSI PRIETOPolicy Officer – International SectorEuropean CommissionDG Agriculture and Rural DevelopmentDirectorate B. Multilateral Relations, Quality Policy+32 2 295 21 [email protected]: [email protected] Dear Manual Rossi Prieto: The following is an overview of instances where QCS provided the European Commissioninformation in regards to certifying processing operations in Ecuador to its EU program: In 2013, QCS submitted the 2012 EC Annual report via the OFIS system. On pages 67 of 450 of the2012 EC Annual report is an assessment report from the USDA AMS that states on page that QCS hasprocessors in Ecuador in compliance with the EU program. On page 77 of 450 of the 2012 EC Annualreport, it also includes CAEQ’s assessment report from 2013, which also mentions a visit to the officein Ecuador by CAEQ in 2010. See Attachment A, QCS EU OFIS 2012 EU Annual report SUB 2013. In 2014, QCS submitted the 2013 EC Annual report via the OFIS system. The 2013 EC Annual reportincludes a report from the USDA AMS that states on page (26 of 318) under StandardsApplied/Scope/Clients and (29 of 318) that QCS has processors in Ecuador in compliance to the EUprogram. See Attachment B, QCS EU 2013 report ARCB00076_report SUB 2014. In 2015, QCS submitted the 2014 EC Annual report via the OFIS system. See Attachment C, QCS EUOFIS 2014 Annual Report SUB 2015. The 2014 EC Annual report includes the following references toQCS performing certification activities in Ecuador for the scope of processing: 1. On page 75 of 412; the 2014 EC Annual report includes a 2014 CAEQ Annual Surveillance reportidentifying the countries with which QCS operates; including Ecuador. Then below, it identifies theprograms included in those countries; which include COS (which is the Canada program) orInternational (which is EU program), and both programs are ticked for the scope of processing. 2. On page 360 of 412; a 2014 USDA NOP Reassessment report clearly makes reference that QCS hasprocessors in Ecuador in compliance to the EU program.

3. On page 363 of 412; a 2014 USDA NOP Witness report makes reference that QCS has processorsin Ecuador in compliance to the EU program. Following submission of the 2014 EC Annual report, on April 29, 2015 , QCS requested EC to updatean error to the OFIS report. The email requested processing/handling in Ecuador for Category D.Although not clearly articulated in the email, the attachment of the Annual Report was provided toshow that our report had Category E listed and not Category D. See Attachment D, QCS Request toUpdate OFIS Report 150429. Please note, we cannot locate any responses from the EC to this emailin our records.

Also for 2015, QCS submitted a geographical scope extension that included a complete list ofoperators in the EU program. The submission included an EU program operator list that includedprocessing operations located in Ecuador. See Attachment E, QCS Request for a Scope Extension. In 2016, QCS submitted the 2015 Annual Report to the EC via their OFIS system. The 2015 Annualreport; includes the same reports from the 2014 OFIS report, see above items 1-3. Also in 2016, CAEQ issued QCS a CAEQ QCS Recognition letter that clearly states that CAEQ hasvisited the Ecuador office and concur the activity of processors in the EU program. This is alsosupported by the CAEQ certificate issued to QCS which identifies both the scope of processing andthe country of Ecuador. See Attachment F, 20160823_CAEQ_letter QCS_EU & Attachment G, 04ISO 17065 Accreditation Certificate_QCS_2015. We appreciate your review of this evidence. If you have any questions please let us know. We hopethis information meets your satisfaction.

Respectfully,

Krista WanserQuality Systems ManagerQuality Certification ServicesPhone: 573-999-5926 ~ Fax: [email protected] Enclosures:Attachments A-B (Email 10f3)Attachments C-D (Email 20f3)Attachments E-F (Email 3of3)

………………………………………………………………………………………………..This message, including all content and attachments, are intended only for the use of theaddressee(s) indicated and may contain information that is privileged, confidential, proprietaryand/or exempt from disclosure under applicable law. If the reader of this message is not theintended recipient, or the employee or agent responsible for delivering the message to the intendedrecipient, you are hereby notified that any dissemination, distribution, copying, downloading, storingor forwarding of this communication is prohibited. If you have received this communication in error,

please notify the sender immediately via email and permanently delete the message and itsattachments.

From: Lewis, Paul I - AMSTo: McEvoy, Miles - AMS; Courtney, Cheri - AMSCc: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Pattillo, Devon - AMSSubject: RE: thank you for joining us on November 15 at the Pre-NOSB meetingDate: Thursday, November 10, 2016 12:47:25 PM

Here are some additional talking points to address organic seed • As a means to prevent GMO contamination in crops, the NOSB is presenting a discussiondocument to strengthening the organic seed guidance (i.e., revised in a way that will lead to greateruse of organic seed) at the November NOSB meeting• A main theme is that producers should be required to increase use of organic seed andplanting stock over time (i.e. continuous improvement) Other points are:o Current guidance is not strong or specific enough to ensure use of organic seedo Largest producers are not using enough organic seedo At-risk crops (prone to GMO contamination) should face greater scrutinyo NOP should promote the Organic Seed Finder (www.organicseedfinder.org); the databasecurrently includes eight seed vendors References:NOP 5029 and response to comments 5029-1NOSB recommendations in 2005 and 2008 Thanks. Paul Paul I. Lewis, Ph.D.Director, Standards DivisionNational Organic ProgramAgricultural Marketing ServiceMarketing and Regulatory ProgramsDepartment of Agriculture202 260 9294

From: McEvoy, Miles - AMS Sent: Tuesday, November 08, 2016 5:04 AMTo: Courtney, Cheri - AMS <[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Lewis, Paul I - AMS<[email protected]>; Gebault King, ReneeA - AMS <[email protected]>Subject: FW: thank you for joining us on November 15 at the Pre-NOSB meeting Please prepare talking points for these questions as they are under AIA responsibilities. Thanks.

From: Abby Youngblood [mailto:[email protected]] Sent: Monday, November 07, 2016 4:52 PMTo: McEvoy, Miles - AMS <[email protected]>Cc: Subject: thank you for joining us on November 15 at the Pre-NOSB meeting Dear Miles,

Thank you for joining us at our Pre-NOSB meeting next week on Tuesday the 15th. I am writing toconfirm that we have you scheduled to take part from 2:30 to 3:30. Are there others from USDA who willbe able to join us? We are planning on a Q&A format, similar to the format we’ve had during the past several meetings. Twoof the topics we would like to discuss are outlined at the end of this message. I will be in touch veryshortly with one or two additional topics. During the meeting, we would like to present each of thesetopics to you, hear your response and have time for some discussion. Here is the general format we havein mind: - 5 min for opening remarks from you- 3 min or less for NOC member to present topic/question- 4 to 5 min for your response- 10 min for discussion If we spend about 15 to 20 minutes on each question, we should be able to finish in the time allotted. We have approximately 50 people planning to attend, including about 20 NOC members, as well as 30others, including farmers, NOSB members, certifiers, animal welfare groups, and organic industrymembers. We appreciate your dedication to organic and your engagement with NOC and others during the meeting.Please do not hesitate to let me know if you have questions. Best Regards,Abby and Steve

1. QUESTION ON ORGANIC SEED

While the allowance for the use of non-organic seed in organic production is important forgrowers who lack access to appropriate organic seed, the organic seed requirement isinconsistently enforced. Many would like to see the NOP do more through guidance andregular trainings to create incentives for farms to use more organic seed and to establish aframework for continuous improvement in the use of organic seed. How can this guidance be strengthened and what else can the NOP do to supportincreased use of organic seed? How will the NOP support tracking organic seed availabilityby crop type and region on an annual basis?

2. QUESTION ON ORGANIC IMPORTS

Over the past few years, there has been a dramatic increase in imports of organic

(b) (6)

commodities, especially grains. A key area of concern for U.S. organic grain growers iswhether these increased imports present an opportunity for fraudulently labeled organicproducts to enter the United States, undermining the opportunity for U.S. producers toget a fair price in the market. Long international supply chains may increase theopportunities for fraud due to breaks in the chain of recordkeeping, organic certificationand verification that the USDA organic seal is built upon. The rise of imports from Turkeyespecially raises concern and one Turkish organic certifier, ETKO, has been decertified bythe EU. The NOP took the step of reminding importers of handling regulations on July 13, 2016,but this action is not enough to address the potential for fraud. What plans does the NOP have to address this issue? Will the NOP require importers to becertified by an NOP accredited certifier going forward? What other systems will the NOPput in place to ensure the integrity of shipments of grains and other commodities?

--Abby Youngblood Executive DirectorNational Organic [email protected]: www.NationalOrganicCoalition.orgTwitter: @NationalOrganicFacebook: Facebook.com/NationalOrganicCoalition

(b) (6)

From: Courtney, Cheri - AMSTo: McEvoy, Miles - AMSCc: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Mann, Renee - AMSSubject: RE: thank you for joining us on November 15 at the Pre-NOSB meetingDate: Thursday, November 10, 2016 2:19:51 PM

Hi Miles,We will have the talking points on Monday.Cheri

From: McEvoy, Miles - AMS Sent: Tuesday, November 08, 2016 5:04 AMTo: Courtney, Cheri - AMS <[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Lewis, Paul I - AMS<[email protected]>; Gebault King, ReneeA - AMS <[email protected]>Subject: FW: thank you for joining us on November 15 at the Pre-NOSB meeting Please prepare talking points for these questions as they are under AIA responsibilities. Thanks. From: Abby Youngblood [mailto:[email protected]] Sent: Monday, November 07, 2016 4:52 PMTo: McEvoy, Miles - AMS <[email protected]>Cc: Subject: thank you for joining us on November 15 at the Pre-NOSB meeting Dear Miles,

Thank you for joining us at our Pre-NOSB meeting next week on Tuesday the 15th. I am writing toconfirm that we have you scheduled to take part from 2:30 to 3:30. Are there others from USDA who willbe able to join us? We are planning on a Q&A format, similar to the format we’ve had during the past several meetings. Twoof the topics we would like to discuss are outlined at the end of this message. I will be in touch veryshortly with one or two additional topics. During the meeting, we would like to present each of thesetopics to you, hear your response and have time for some discussion. Here is the general format we havein mind: - 5 min for opening remarks from you- 3 min or less for NOC member to present topic/question- 4 to 5 min for your response- 10 min for discussion If we spend about 15 to 20 minutes on each question, we should be able to finish in the time allotted. We have approximately 50 people planning to attend, including about 20 NOC members, as well as 30others, including farmers, NOSB members, certifiers, animal welfare groups, and organic industrymembers. We appreciate your dedication to organic and your engagement with NOC and others during the meeting.Please do not hesitate to let me know if you have questions. Best Regards,

(b) (6)

Abby and Steve


While the allowance for the use of non-organic seed in organic production is important forgrowers who lack access to appropriate organic seed, the organic seed requirement isinconsistently enforced. Many would like to see the NOP do more through guidance andregular trainings to create incentives for farms to use more organic seed and to establish aframework for continuous improvement in the use of organic seed. How can this guidance be strengthened and what else can the NOP do to supportincreased use of organic seed? How will the NOP support tracking organic seed availabilityby crop type and region on an annual basis?


Over the past few years, there has been a dramatic increase in imports of organiccommodities, especially grains. A key area of concern for U.S. organic grain growers iswhether these increased imports present an opportunity for fraudulently labeled organicproducts to enter the United States, undermining the opportunity for U.S. producers toget a fair price in the market. Long international supply chains may increase theopportunities for fraud due to breaks in the chain of recordkeeping, organic certificationand verification that the USDA organic seal is built upon. The rise of imports from Turkeyespecially raises concern and one Turkish organic certifier, ETKO, has been decertified bythe EU. The NOP took the step of reminding importers of handling regulations on July 13, 2016,but this action is not enough to address the potential for fraud. What plans does the NOP have to address this issue? Will the NOP require importers to becertified by an NOP accredited certifier going forward? What other systems will the NOPput in place to ensure the integrity of shipments of grains and other commodities?

--Abby Youngblood Executive Director

National Organic [email protected]: www.NationalOrganicCoalition.orgTwitter: @NationalOrganicFacebook: Facebook.com/NationalOrganicCoalition

(b) (6)

From: Gebault King, ReneeA - AMSTo: "Marlene Moore"Cc: Susan M Ranck; Jean Richardson; Jim Riddle; Yang, RobertH - AMS; Courtney, Cheri - AMS; Elizabeth Okutuga;

Reinaldo FigueiredoSubject: RE: USDA NOP files availableDate: Saturday, May 14, 2016 7:34:00 AMAttachments: image001.png

image002.png

Hello, Marlene, The sub-folders in the BAR-O file have been reloaded and should be available to you and your team.Please let me know if there are still issues with access. Kind regards,

Renée



From: Marlene Moore [mailto:[email protected]] Sent: Friday, May 13, 2016 3:18 PMTo: Gebault King, ReneeA - AMS <[email protected]>Cc: Susan M Ranck <[email protected]>; Jean Richardson

; Jim Riddle <[email protected]>; Yang, RobertH - AMS<[email protected]>; Courtney, Cheri - AMS <[email protected]>; ElizabethOkutuga <[email protected]>; Reinaldo Figueiredo <[email protected]>Subject: Re: USDA NOP files available Renee I can open the files, but it seems that some files are missing Uncer corrective action I have NC1 to 8 and 5 tild files now I only see two

(b) (6)

(b) (6)


>; Jim Riddle <[email protected]>; Yang, RobertH - AMS<[email protected]>; Courtney, Cheri - AMS<[email protected]>; Elizabeth Okutuga <[email protected]>; ReinaldoFigueiredo <[email protected]>Subject: Re: USDA NOP files available Renee I was able to download the zip files - Bar-O: I have not reviewed all, but I see this file which I cannot open~$5264EEA NC rept 12 18 15 (This is in folder NoNC) There are several files under Corr Action Response with the same tild (~) mark atthe start of the file name - these do not open either. Do you know what it is not readable? M

On May 13, 2016, at 2:43 PM, Gebault King, ReneeA - AMS<[email protected]> wrote: Dear Marlene, The following files have been uploaded to CloudVault and are available foryou:

1. Basin and Range Organics (BAR-O)2. Primus Labs3. Ecological Farming Control Organization (ETKO)4. Ecocert ICO5. Texas Department of Ag

These files are provided in compressed or “.zip” format. Please let meknow if you have issues with access. Kind regards,

Renée


(b) (6)

Office: 202.690.1312 | Mobile: [email protected] USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South,Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax:202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

This electronic message contains information generated by the USDAsolely for the intended recipients. Any unauthorized interception of thismessage or the use or disclosure of the information it contains mayviolate the law and subject the violator to civil or criminal penalties. Ifyou believe you have received this message in error, please notify thesender and delete the email immediately.

_________________________________All replies to: [email protected]

Advanced Systems, Inc. - Quality Systems Design, Auditing and Training P.O. Box 8032, Newark, DE 19714Voice: 302-368-1211, Fax: 720-293-3706

Advanced Systems cannot be responsible for the confidentiality of electronicallytransmitted data unless prior arrangements have been made.



Advanced Systems cannot be responsible for the confidentiality of electronically transmitteddata unless prior arrangements have been made.

(b) (6)

From: Marlene MooreTo: Gebault King, ReneeA - AMSCc: Susan M Ranck; Jean Richardson; Jim Riddle; Yang, RobertH - AMS; Courtney, Cheri - AMS; Elizabeth Okutuga;

Reinaldo FigueiredoSubject: Re: USDA NOP files availableDate: Friday, May 13, 2016 3:18:08 PMAttachments: Screen Shot 2016-05-13 at 3.15.34 PM.png

Screen Shot 2016-05-13 at 3.16.22 PM.png

Renee

I can open the files, but it seems that some files are missing

Uncer corrective action I have NC1 to 8 and 5 tild files now I only see two

5 tilde

On May 13, 2016, at 3:09 PM, Gebault King, ReneeA - AMS <[email protected]> wrote:

Hello, Marlene, I have reloaded the BAR-O file directly (not “zip”) into CloudVault. Please let me know if you continue to have issues with file access. Kind regards, Renée

Renée Gebault King, Ph.D.Accreditation Manager Office: 202.690.1312 | [email protected] USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South, Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail! From: Marlene Moore [mailto:[email protected]] Sent: Friday, May 13, 2016 2:58 PMTo: Gebault King, ReneeA - AMS <[email protected]>Cc: Susan M Ranck <[email protected]>; Jean Richardson

>; Jim Riddle <[email protected]>; Yang, RobertH - AMS <[email protected]>; Courtney, Cheri - AMS <[email protected]>; Elizabeth Okutuga <[email protected]>; Reinaldo Figueiredo <[email protected]>Subject: Re: USDA NOP files available Renee I was able to download the zip files - Bar-O: I have not reviewed all, but I see this file which I cannot open~$5264EEA NC rept 12 18 15 (This is in folder NoNC) There are several files under Corr Action Response with the same tild (~) mark at the start of the file name - these do not open either. Do you know what it is not readable? M

On May 13, 2016, at 2:43 PM, Gebault King, ReneeA - AMS <[email protected]> wrote: Dear Marlene, The following files have been uploaded to CloudVault and are available for you:

1. Basin and Range Organics (BAR-O)2. Primus Labs

(b) (6)

(b) (6)

3. Ecological Farming Control Organization (ETKO)4. Ecocert ICO5. Texas Department of Ag

These files are provided in compressed or “.zip” format. Please let me know if you have issues with access. Kind regards,

Renée



This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately.



Advanced Systems cannot be responsible for the confidentiality of electronically transmitted data unless prior arrangements have been made.


Advanced Systems, Inc. - Quality Systems Design, Auditing and

(b) (6)

Training P.O. Box 8032, Newark, DE 19714Voice: 302-368-1211, Fax: 720-293-3706



Reinaldo FigueiredoSubject: RE: USDA NOP files availableDate: Friday, May 13, 2016 3:09:00 PM

Hello, Marlene, I have reloaded the BAR-O file directly (not “zip”) into CloudVault. Please let me know if youcontinue to have issues with file access. Kind regards,

Renée




>; Jim Riddle <[email protected]>; Yang, RobertH - AMS<[email protected]>; Courtney, Cheri - AMS <[email protected]>; ElizabethOkutuga <[email protected]>; Reinaldo Figueiredo <[email protected]>Subject: Re: USDA NOP files available Renee I was able to download the zip files - Bar-O: I have not reviewed all, but I see this file which I cannot open~$5264EEA NC rept 12 18 15 (This is in folder NoNC) There are several files under Corr Action Response with the same tild (~) mark at the start ofthe file name - these do not open either.

(b) (6)

(b) (6)

Do you know what it is not readable? M

On May 13, 2016, at 2:43 PM, Gebault King, ReneeA - AMS<[email protected]> wrote: Dear Marlene, The following files have been uploaded to CloudVault and are available for you:


These files are provided in compressed or “.zip” format. Please let me know if you haveissues with access. Kind regards,

Renée


Office: 202.690.1312 | [email protected] USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South, Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

This electronic message contains information generated by the USDA solely for theintended recipients. Any unauthorized interception of this message or the use ordisclosure of the information it contains may violate the law and subject the violatorto civil or criminal penalties. If you believe you have received this message in error,please notify the sender and delete the email immediately.


Advanced Systems, Inc. - Quality Systems Design, Auditing and

(b) (6)

Training P.O. Box 8032, Newark, DE 19714Voice: 302-368-1211, Fax: 720-293-3706


From: Marlene MooreTo: Gebault King, ReneeA - AMSCc: Susan M Ranck; Jean Richardson; Jim Riddle; Yang, RobertH - AMS; Courtney, Cheri - AMS; Elizabeth Okutuga;

Reinaldo FigueiredoSubject: Re: USDA NOP files availableDate: Friday, May 13, 2016 2:57:41 PM

Renee

I was able to download the zip files -

Bar-O: I have not reviewed all, but I see this file which I cannot open~$5264EEA NC rept 12 18 15 (This is in folder NoNC)

There are several files under Corr Action Response with the same tild (~) mark at the start of the file name - these do not open either.

Do you know what it is not readable?

M

On May 13, 2016, at 2:43 PM, Gebault King, ReneeA - AMS <[email protected]> wrote:

Dear Marlene, The following files have been uploaded to CloudVault and are available for you:


These files are provided in compressed or “.zip” format. Please let me know if you have issues with access. Kind regards,

Renée Renée Gebault King, Ph.D.Accreditation Manager Office: 202.690.1312 | Mobile: [email protected]

(b) (6)

USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South, Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately.





Reinaldo FigueiredoSubject: RE: USDA NOP files availableDate: Saturday, May 14, 2016 7:34:00 AMAttachments: image001.png

image002.png

Hello, Marlene, The sub-folders in the BAR-O file have been reloaded and should be available to you and your team.Please let me know if there are still issues with access. Kind regards,

Renée




>; Jim Riddle <[email protected]>; Yang, RobertH - AMS<[email protected]>; Courtney, Cheri - AMS <[email protected]>; ElizabethOkutuga <[email protected]>; Reinaldo Figueiredo <[email protected]>Subject: Re: USDA NOP files available Renee I can open the files, but it seems that some files are missing Uncer corrective action I have NC1 to 8 and 5 tild files now I only see two

(b) (6)

(b) (6)


>; Jim Riddle <[email protected]>; Yang, RobertH - AMS<[email protected]>; Courtney, Cheri - AMS<[email protected]>; Elizabeth Okutuga <[email protected]>; ReinaldoFigueiredo <[email protected]>Subject: Re: USDA NOP files available Renee I was able to download the zip files - Bar-O: I have not reviewed all, but I see this file which I cannot open~$5264EEA NC rept 12 18 15 (This is in folder NoNC) There are several files under Corr Action Response with the same tild (~) mark atthe start of the file name - these do not open either. Do you know what it is not readable? M

On May 13, 2016, at 2:43 PM, Gebault King, ReneeA - AMS<[email protected]> wrote: Dear Marlene, The following files have been uploaded to CloudVault and are available foryou:


These files are provided in compressed or “.zip” format. Please let meknow if you have issues with access. Kind regards,

Renée


(b) (6)

Office: 202.690.1312 | Mobile: [email protected] USDA National Organic Program | 1400 Independence Ave SW | Room 2649-South,Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax:202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

This electronic message contains information generated by the USDAsolely for the intended recipients. Any unauthorized interception of thismessage or the use or disclosure of the information it contains mayviolate the law and subject the violator to civil or criminal penalties. Ifyou believe you have received this message in error, please notify thesender and delete the email immediately.



Advanced Systems cannot be responsible for the confidentiality of electronicallytransmitted data unless prior arrangements have been made.




(b) (6)

From: McEvoy, Miles - AMSTo: Strzelecki, Kelly - FAS; Gebault King, ReneeA - AMS; Courtney, Cheri - AMS; Doherty, JuliaSubject: RE: US-EU DVC draft minutesDate: Friday, April 01, 2016 10:03:49 AMAttachments: 160202 OWG DRAFT minutes ks mvm.doc

I have some additional edits. Miles

From: Strzelecki, Kelly - FAS Sent: Tuesday, March 22, 2016 10:16 AMTo: Gebault King, ReneeA - AMS <[email protected]>; McEvoy, Miles - AMS<[email protected]>; Courtney, Cheri - AMS <[email protected]>; Doherty,Julia <[email protected]>Subject: RE: US-EU DVC draft minutes Thanks Renee, the attached includes a few edits.Kelly Kelly StrzeleckiSenior Trade AdvisorProcessed Products & Technical Regulations DivisionOffice of Agreements and Scientific AffairsUSDA/Foreign Agricultural Service(202) 690-0522

From: Gebault King, ReneeA - AMS Sent: Friday, March 18, 2016 3:45 PMTo: McEvoy, Miles - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: US-EU DVC draft minutes Hello, Team- Attached please find the draft minutes from the 2 Feb. 2016 DVC with the EU. Please review at your earliest convenience. Enter any comments or edits in “track changes” mode. Thank you!

Renée GK


(b) (6)



Note to the file







February-April:





2


April-July


September-October












On Costa Rica, US confirmed interest in having equivalency recognition but there are significant concerns about pineapple and bananas production.

3

5. Update on ETKO





US informed that the adoption of aquaculture standards has been postponed.

8. AOB

OFIS irregularities: EC called US attention again to the delays in replying to OFIS irregularities' notifications. US is the country with the worst record in replying late. This is public information shared with EU Member States and could damage US image. US expressed its willingness to improve the situation.


Manuel ROSSI PRIETO

From: Strzelecki, Kelly - FASTo: Gebault King, ReneeA - AMS; McEvoy, Miles - AMS; Courtney, Cheri - AMS; Doherty, JuliaSubject: RE: US-EU DVC draft minutesDate: Tuesday, March 22, 2016 10:16:17 AMAttachments: 160202 OWG DRAFT minutes ks.doc

Thanks Renee, the attached includes a few edits.Kelly Kelly StrzeleckiSenior Trade AdvisorProcessed Products & Technical Regulations DivisionOffice of Agreements and Scientific AffairsUSDA/Foreign Agricultural Service(202) 690-0522

From: Gebault King, ReneeA - AMS Sent: Friday, March 18, 2016 3:45 PMTo: McEvoy, Miles - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: US-EU DVC draft minutes Hello, Team- Attached please find the draft minutes from the 2 Feb. 2016 DVC with the EU. Please review at your earliest convenience. Enter any comments or edits in “track changes” mode. Thank you!

Renée GK


(b) (6)



Note to the file







February-April:





2


April-July


September-October












On Costa Rica, US confirmed interest in having equivalency recognition but there are significant concerns about Costa Rica’s lack of investigation and enforcement on fraudulent pineapple products and bananas production.

3

5. Update on ETKO





US informed that the adoption of aquaculture standards has been postponedslowed but still plan to have a proposal out later in 2016.

8. AOB

OFIS irregularities: EC called US attention again to the delays in replying to OFIS irregularities' notifications. US is the country with the worst record in replying late. This is public information shared with EU Member States and could damage US image. US expressed its willingness to discussimprove the situation. US subsequently met via teleconference with EU on February 22, 2016, to clarify EU expectations regarding irregularity closure, especially given the complexity and age of many of the EU irregularity findings. This meeting has resulted in significant progress in irregularity resolution by the US.


Manuel ROSSI PRIETO

From: McEvoy, Miles - AMSTo: Jones, Samuel - AMS; Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Holmes, Vella - AMSCc: Courtney, Cheri - AMSSubject: RE: WSJ Follow-up QuestionsDate: Thursday, January 12, 2017 6:08:12 PM

1. When was the most recent audit of ETKO? [NOP] Witness audits were conducted in Ukraine in October 2016.

2. Were any actions taken against ETKO based off of complaints received?

[NOP] We have not received any complaints against ETKO. We have received complaintsabout organic corn imports from Turkey. An investigation is currently in progress.

3. Did Canada or the EU share compliance information about ETKO and why they took actionagainst the certifier?

[NOP] The NOP has copies of the audit reports that led to EU and Canadian sanctions againstETKO. ETKO was suspended by the EU and is not allowed to issue EU organic certificationuntil the EU has determined that ETKO is in full compliance. Additionally, The Canadian FoodInspection Agency notified NOP of ETKO suspension and cancelation of ETKO accreditation. Specific information regarding CFIA actions is located on CFIA website.

4. If a company or ACA gets in trouble with a country that we have an equivalency arrangementwith, does that company get in trouble with the US as well? In not, why? [NOP] Eachgovernment has independent processes for reviewing, auditing and approving certifyingagents. Under the US system we have specific compliance procedures which provide dueprocess rights to certified farms, handlers and certifiers when noncompliances are identified.

5. Do we have any stats on the amount/type of products that ETKO certifies?

[NOP] We have what is listed on the Organic Integrity Database. Each certified operationlists the type of organic products are produced and/or handled. There is no information onquantity.

6. Is there a master schedule of all ACA audits that we can share? [NOP] We post all auditreports once they are finalized.

Miles McEvoyDeputy AdministratorNational Organic Program

From: Jones, Samuel - AMS Sent: Tuesday, January 10, 2017 2:04 PMTo: McEvoy, Miles - AMS <[email protected]>; Tucker, Jennifer - AMS<[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>Subject: WSJ Follow-up Questions

Good afternoon, Last week, Miles did an interview with the WSJ on organic imports. The reporter has thefollowing follow-up questions I could use some help on. Ideally, he would like responses bythe end of the week.

1. When was the most recent audit of ETKO?2. Were any actions taken against ETKO based off of complaints received?3. Did Canada or the EU share compliance information about ETKO and why they took

action against the certifier?4. If a company or ACA gets in trouble with a country that we have an equivalency

arrangement with, does that company get in trouble with the US as well? In not, why?5. Do we have any stats on the amount/type of products that ETKO certifies? 6. Is there a master schedule of all ACA audits that we can share?

Thanks in advance! Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA AMS or read our stories on the USDA blog.

From: Tucker, Jennifer - AMSTo: Courtney, Cheri - AMS; Mann, Renee - AMSCc: Gebault King, ReneeA - AMS; Holmes, Vella - AMS; Jones, Samuel - AMS; McEvoy, Miles - AMSSubject: RE: WSJ Follow-up QuestionsDate: Monday, January 23, 2017 9:38:39 AM

Cheri and Renee – If you could send me quick answers to below, I can frame as a draft response forMiles’ review.Thanks –Jenny

From: Jones, Samuel - AMS Sent: Friday, January 20, 2017 11:17 AMTo: McEvoy, Miles - AMS <[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>;Courtney, Cheri - AMS <[email protected]>Subject: RE: WSJ Follow-up Questions Good morning, We received a few more follow-up questions from the WSJ. The reporter would likeresponses back next week. Thanks in advance!

1. Why was a settlement agreement agreed upon with ETKO instead of a suspension?2. Have all issues of noncompliance with ETKO been corrected?3. Are there any outstanding complaints or investigations related to ETKO?4. What was the nature of the violations that led to the settlement agreement with ETKO?

Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA_AMS or read our stories on the USDA blog. From: Jones, Samuel - AMS Sent: Thursday, January 12, 2017 6:37 PMTo: McEvoy, Miles - AMS <[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>;Courtney, Cheri - AMS <[email protected]>Subject: Re: WSJ Follow-up Questions Thanks for pulling this together!

Sam Jones-Ellard

USDA's Agricultural Marketing ServicePublic Affairs202.660.2268 Sent from my iPhone

On Jan 12, 2017, at 6:08 PM, McEvoy, Miles - AMS <[email protected]> wrote:



[NOP] We have not received any complaints against ETKO. We have receivedcomplaints about organic corn imports from Turkey. An investigation iscurrently in progress.

3. Did Canada or the EU share compliance information about ETKO and why theytook action against the certifier?

[NOP] The NOP has copies of the audit reports that led to EU and Canadiansanctions against ETKO. ETKO was suspended by the EU and is not allowed toissue EU organic certification until the EU has determined that ETKO is in fullcompliance. Additionally, The Canadian Food Inspection Agency notified NOP ofETKO suspension and cancelation of ETKO accreditation. Specific informationregarding CFIA actions is located on CFIA website.

4. If a company or ACA gets in trouble with a country that we have an equivalencyarrangement with, does that company get in trouble with the US as well? In not,why? [NOP] Each government has independent processes for reviewing, auditingand approving certifying agents. Under the US system we have specificcompliance procedures which provide due process rights to certified farms,handlers and certifiers when noncompliances are identified.


[NOP] We have what is listed on the Organic Integrity Database. Each certifiedoperation lists the type of organic products are produced and/or handled. There is no information on quantity.

6. Is there a master schedule of all ACA audits that we can share? [NOP] We postall audit reports once they are finalized.


From: Jones, Samuel - AMS Sent: Tuesday, January 10, 2017 2:04 PMTo: McEvoy, Miles - AMS <[email protected]>; Tucker, Jennifer - AMS<[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS<[email protected]>Subject: WSJ Follow-up Questions Good afternoon, Last week, Miles did an interview with the WSJ on organic imports. The reporterhas the following follow-up questions I could use some help on. Ideally, he wouldlike responses by the end of the week.

1. When was the most recent audit of ETKO?2. Were any actions taken against ETKO based off of complaints received?3. Did Canada or the EU share compliance information about ETKO and

why they took action against the certifier?4. If a company or ACA gets in trouble with a country that we have an

equivalency arrangement with, does that company get in trouble with theUS as well? In not, why?

5. Do we have any stats on the amount/type of products that ETKOcertifies?

6. Is there a master schedule of all ACA audits that we can share?

Thanks in advance! Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA AMS or read our stories on the USDA blog.

From: Tucker, Jennifer - AMSTo: Jones, Samuel - AMSCc: McEvoy, Miles - AMS; Gebault King, ReneeA - AMS; Holmes, Vella - AMS; Courtney, Cheri - AMSSubject: Re: WSJ Follow-up QuestionsDate: Friday, January 20, 2017 1:39:50 PM

FYI - we also just recently received a FOIA for ETKO appeal records related to the settlementagreement – we will be releasing appeals records to John Bobbe, OFARM Executive Director.And, posting on our website.

On Jan 20, 2017, at 11:16 AM, "Jones, Samuel - AMS" <[email protected]>wrote:

Good morning, We received a few more follow-up questions from the WSJ. The reporter wouldlike responses back next week. Thanks in advance!

1. Why was a settlement agreement agreedupon with ETKO instead of a suspension?

2. Have all issues of noncompliance withETKO been corrected?

3. Are there any outstanding complaints orinvestigations related to ETKO?

4. What was the nature of the violationsthat led to the settlement agreement with ETKO?

Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA_AMS or read our stories on the USDA blog. From: Jones, Samuel - AMS Sent: Thursday, January 12, 2017 6:37 PMTo: McEvoy, Miles - AMS <[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Gebault King, ReneeA -AMS <[email protected]>; Holmes, Vella - AMS<[email protected]>; Courtney, Cheri - AMS<[email protected]>Subject: Re: WSJ Follow-up Questions Thanks for pulling this together!

Sam Jones-EllardUSDA's Agricultural Marketing ServicePublic Affairs

202.660.2268 Sent from my iPhone

On Jan 12, 2017, at 6:08 PM, McEvoy, Miles - AMS <[email protected]>wrote:


2. Were any actions taken against ETKO based off of complaints

received?[NOP] We have not received any complaints against ETKO. Wehave received complaints about organic corn imports from Turkey.An investigation is currently in progress.

3. Did Canada or the EU share compliance information about ETKOand why they took action against the certifier?

[NOP] The NOP has copies of the audit reports that led to EU andCanadian sanctions against ETKO. ETKO was suspended by the EUand is not allowed to issue EU organic certification until the EU hasdetermined that ETKO is in full compliance. Additionally, TheCanadian Food Inspection Agency notified NOP of ETKOsuspension and cancelation of ETKO accreditation. Specificinformation regarding CFIA actions is located on CFIA website.

4. If a company or ACA gets in trouble with a country that we have anequivalency arrangement with, does that company get in troublewith the US as well? In not, why? [NOP] Each government hasindependent processes for reviewing, auditing and approvingcertifying agents. Under the US system we have specific complianceprocedures which provide due process rights to certified farms,handlers and certifiers when noncompliances are identified.

5. Do we have any stats on the amount/type of products that ETKO

certifies? [NOP] We have what is listed on the Organic Integrity Database. Each certified operation lists the type of organic products areproduced and/or handled. There is no information on quantity.

6. Is there a master schedule of all ACA audits that we canshare? [NOP] We post all audit reports once they are finalized.

Miles McEvoyDeputy Administrator

National Organic Program

From: Jones, Samuel - AMS Sent: Tuesday, January 10, 2017 2:04 PMTo: McEvoy, Miles - AMS <[email protected]>; Tucker,Jennifer - AMS <[email protected]>; Gebault King, ReneeA -AMS <[email protected]>; Holmes, Vella - AMS<[email protected]>Subject: WSJ Follow-up Questions Good afternoon, Last week, Miles did an interview with the WSJ on organic imports. The reporter has the following follow-up questions I could use somehelp on. Ideally, he would like responses by the end of the week.

1. When was the most recentaudit of ETKO?

2. Were any actions takenagainst ETKO based off of complaints received?

3. Did Canada or the EU sharecompliance information about ETKO and why they tookaction against the certifier?

4. If a company or ACA getsin trouble with a country that we have an equivalencyarrangement with, does that company get in trouble with theUS as well? In not, why?

5. Do we have any stats on theamount/type of products that ETKO certifies?

6. Is there a master schedule ofall ACA audits that we can share?

Thanks in advance! Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA_AMS or read our stories on the USDA blog.

From: Jones, Samuel - AMSTo: McEvoy, Miles - AMSCc: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Holmes, Vella - AMS; Courtney, Cheri - AMSSubject: RE: WSJ Follow-up QuestionsDate: Friday, January 20, 2017 11:16:44 AM

Good morning, We received a few more follow-up questions from the WSJ. The reporter would likeresponses back next week. Thanks in advance!

1. Why was a settlement agreement agreed upon with ETKO instead of a suspension?2. Have all issues of noncompliance with ETKO been corrected?3. Are there any outstanding complaints or investigations related to ETKO?4. What was the nature of the violations that led to the settlement agreement with ETKO?

Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA AMS or read our stories on the USDA blog. From: Jones, Samuel - AMS Sent: Thursday, January 12, 2017 6:37 PMTo: McEvoy, Miles - AMS <[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>;Courtney, Cheri - AMS <[email protected]>Subject: Re: WSJ Follow-up Questions Thanks for pulling this together!

Sam Jones-EllardUSDA's Agricultural Marketing ServicePublic Affairs202.660.2268 Sent from my iPhone




[NOP] We have not received any complaints against ETKO. We have receivedcomplaints about organic corn imports from Turkey. An investigation is

currently in progress.






6. Is there a master schedule of all ACA audits that we can share? [NOP] We postall audit reports once they are finalized.



1. When was the most recent audit of ETKO?

2. Were any actions taken against ETKO based off of complaints received?3. Did Canada or the EU share compliance information about ETKO and

why they took action against the certifier?4. If a company or ACA gets in trouble with a country that we have an

equivalency arrangement with, does that company get in trouble with theUS as well? In not, why?

5. Do we have any stats on the amount/type of products that ETKOcertifies?

6. Is there a master schedule of all ACA audits that we can share?


From: Jones, Samuel - AMSTo: McEvoy, Miles - AMSCc: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Holmes, Vella - AMS; Courtney, Cheri - AMSSubject: Re: WSJ Follow-up QuestionsDate: Thursday, January 12, 2017 6:37:18 PM

Thanks for pulling this together!

Sam Jones-EllardUSDA's Agricultural Marketing ServicePublic Affairs202.660.2268

Sent from my iPhone




[NOP] We have not received any complaints against ETKO. We have receivedcomplaints about organic corn imports from Turkey. An investigation iscurrently in progress.






6. Is there a master schedule of all ACA audits that we can share? [NOP] We post

all audit reports once they are finalized. Miles McEvoyDeputy AdministratorNational Organic Program


1. When was the most recent audit ofETKO?

2. Were any actions taken against ETKObased off of complaints received?

3. Did Canada or the EU share complianceinformation about ETKO and why they took action against the certifier?

4. If a company or ACA gets in troublewith a country that we have an equivalency arrangement with, does thatcompany get in trouble with the US as well? In not, why?

5. Do we have any stats on the amount/typeof products that ETKO certifies?

6. Is there a master schedule of all ACAaudits that we can share?

From: Courtney, Cheri - AMSTo: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Jones, Samuel - AMS; McEvoy, Miles - AMS; Holmes, Vella -

AMS; Mann, Renee - AMS; Crail, Lars - AMSSubject: RE: WSJ Follow-up QuestionsDate: Tuesday, January 10, 2017 3:47:52 PM

We are already working on a response. Cheri

From: Tucker, Jennifer - AMS Sent: Tuesday, January 10, 2017 3:09 PMTo: Gebault King, ReneeA - AMS <[email protected]>; Jones, Samuel - AMS<[email protected]>; McEvoy, Miles - AMS <[email protected]>; Holmes,Vella - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Mann, Renee - AMS <[email protected]>; Crail, Lars -AMS <[email protected]>Subject: RE: WSJ Follow-up Questions AIA – Please take the lead in developing a response to these. For reference, the ETKO settlementagreement with the NOP is posted at:https://www.ams.usda.gov/sites/default/files/media/NOPSettlementETKO.pdf

From: Gebault King, ReneeA - AMS Sent: Tuesday, January 10, 2017 2:11 PMTo: Jones, Samuel - AMS <[email protected]>; McEvoy, Miles - AMS<[email protected]>; Tucker, Jennifer - AMS <[email protected]>; Holmes,Vella - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Mann, Renee - AMS <[email protected]>; Crail, Lars -AMS <[email protected]>Subject: RE: WSJ Follow-up Questions Looping in Cheri, ReneeM and Lars. Thanks,

Renée GK

From: Jones, Samuel - AMS Sent: Tuesday, January 10, 2017 2:04 PMTo: McEvoy, Miles - AMS <[email protected]>; Tucker, Jennifer - AMS<[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>Subject: WSJ Follow-up Questions Good afternoon,

Last week, Miles did an interview with the WSJ on organic imports. The reporter has thefollowing follow-up questions I could use some help on. Ideally, he would like responses bythe end of the week.





From: Tucker, Jennifer - AMSTo: Gebault King, ReneeA - AMS; Jones, Samuel - AMS; McEvoy, Miles - AMS; Holmes, Vella - AMS; Courtney, Cheri -

AMS; Mann, Renee - AMS; Crail, Lars - AMSSubject: RE: WSJ Follow-up QuestionsDate: Tuesday, January 10, 2017 3:08:47 PM

AIA – Please take the lead in developing a response to these. For reference, the ETKO settlementagreement with the NOP is posted at:https://www.ams.usda.gov/sites/default/files/media/NOPSettlementETKO.pdf

From: Gebault King, ReneeA - AMS Sent: Tuesday, January 10, 2017 2:11 PMTo: Jones, Samuel - AMS <[email protected]>; McEvoy, Miles - AMS<[email protected]>; Tucker, Jennifer - AMS <[email protected]>; Holmes,Vella - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Mann, Renee - AMS <[email protected]>; Crail, Lars -AMS <[email protected]>Subject: RE: WSJ Follow-up Questions Looping in Cheri, ReneeM and Lars. Thanks,

Renée GK

From: Jones, Samuel - AMS Sent: Tuesday, January 10, 2017 2:04 PMTo: McEvoy, Miles - AMS <[email protected]>; Tucker, Jennifer - AMS<[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>Subject: WSJ Follow-up Questions Good afternoon, Last week, Miles did an interview with the WSJ on organic imports. The reporter has thefollowing follow-up questions I could use some help on. Ideally, he would like responses bythe end of the week.




Thanks in advance!

Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA_AMS or read our stories on the USDA blog.

From: Jones, Samuel - AMSTo: Gebault King, ReneeA - AMSSubject: RE: WSJ Follow-up QuestionsDate: Tuesday, January 10, 2017 2:18:42 PM

Thanks! Sam Jones-EllardPublic Affairs SpecialistUSDA | Agricultural Marketing Service202.660.2268 Follow us on Twitter @USDA AMS or read our stories on the USDA blog. From: Gebault King, ReneeA - AMS Sent: Tuesday, January 10, 2017 2:11 PMTo: Jones, Samuel - AMS <[email protected]>; McEvoy, Miles - AMS<[email protected]>; Tucker, Jennifer - AMS <[email protected]>; Holmes,Vella - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Mann, Renee - AMS <[email protected]>; Crail, Lars -AMS <[email protected]>Subject: RE: WSJ Follow-up Questions Looping in Cheri, ReneeM and Lars. Thanks,

Renée GK

From: Jones, Samuel - AMS Sent: Tuesday, January 10, 2017 2:04 PMTo: McEvoy, Miles - AMS <[email protected]>; Tucker, Jennifer - AMS<[email protected]>; Gebault King, ReneeA - AMS<[email protected]>; Holmes, Vella - AMS <[email protected]>Subject: WSJ Follow-up Questions Good afternoon, Last week, Miles did an interview with the WSJ on organic imports. The reporter has thefollowing follow-up questions I could use some help on. Ideally, he would like responses bythe end of the week.



arrangement with, does that company get in trouble with the US as well? In not, why?

5. Do we have any stats on the amount/type of products that ETKO certifies? 6. Is there a master schedule of all ACA audits that we can share?


From: Gebault King, ReneeA - AMSTo: "Marlene Moore"; Susan M Ranck; Jean Richardson; Jim RiddleCc: Yang, RobertH - AMS; Courtney, Cheri - AMS; Elizabeth Okutuga; Reinaldo FigueiredoSubject: USDA NOP files availableDate: Friday, May 13, 2016 2:43:00 PM

Dear Marlene, The following files have been uploaded to CloudVault and are available for you:


These files are provided in compressed or “.zip” format. Please let me know if you have issues withaccess. Kind regards,

Renée



(b) (6)

From: Gebault King, ReneeA - AMSTo: McEvoy, Miles - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: US-EU DVC draft minutesDate: Friday, March 18, 2016 3:44:00 PMAttachments: 160202 OWG DRAFT minutes.doc

Hello, Team- Attached please find the draft minutes from the 2 Feb. 2016 DVC with the EU. Please review at your earliest convenience. Enter any comments or edits in “track changes” mode. Thank you!

Renée GK

USDA NOPOffice: 202.690.1312 | [email protected]

(b) (6)



Note to the file







February-April:





2


April-July


September-October








On Mexico, US informed that an on-site inspection will take place in March. The goal is to conclude negotiations by fall 2016. EC explained that it will try to close its negotiations immediately after and asked US to share the equivalency assessment.


On Taiwan, US informed about a peer review that will take place in US in March. Not full equivalency expected. US aim to ensure products access to Taiwan. EC referred to alternative solutions as the recognition of Taiwan's control authority.



3

5. Update on ETKO






8. AOB



Manuel ROSSI PRIETO

From: Jones, Samuel - AMSTo: McEvoy, Miles - AMS; Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Holmes, Vella - AMSSubject: WSJ Follow-up QuestionsDate: Tuesday, January 10, 2017 2:04:19 PM

Good afternoon, Last week, Miles did an interview with the WSJ on organic imports. The reporter has thefollowing follow-up questions I could use some help on. Ideally, he would like responses bythe end of the week.





From: Crail, Lars - AMSTo: Courtney, Cheri - AMS; Davis, Graham - AMS; Gebault King, ReneeA - AMS; Reid, John - AMS; Lopez, JasonJ -

AMS; Pattillo, Devon - AMS; Claypool, Rebecca E - AMS; Backus, Sonya - AMS; Yang, RobertH - AMS; Zuck,Penelope - AMS; Adams, Edith - AMS; Caceres, Miguel - AMS; Friesenhahn, Martin - AMS; Gebel, Kelley - AMS;Heckart, Patricia - AMS; Kohles, Alan - AMS; Lopez, Mike - AMS; Ross, Steve - AMS

Subject: Auditor Memo 16 - 10 2017 Audit ScheduleDate: Wednesday, December 21, 2016 5:19:35 PMAttachments: image001.png

2017 CY audit plan 12 20 16.xlsx

NOP and QAD Auditors: Attached is a copy of the 2017 NOP Audit Schedule and below is a link where the current version ofthe schedule is maintained: P:\AIA\Audit Planning - Calendar Year\2017 The schedule changes frequently as I receive information regarding confirmation of the Audit ID anddates throughout the year. It is important that you check the schedule frequently for updates(additional audits, audit postponement, etc…). The proposed audits are identified with a month. The month is the preferred timeframe the auditshould occur; however, the assigned Lead Auditor has some discretion to propose an alternatemonth/date for compelling reasons. Review the audit schedule to see if you are assigned as the Lead Auditor or other assigned role. Ifyou are the Lead Auditor, coordinate your audit planning and activities with the rest of the auditteam and me. If you are the Lead Auditor, please contact the certifiers by January 15 and notifythem of the proposed month you intend to conduct the audit. If you have any questions, please contact me. Lars CrailUSDA NOP202.205.5536 office

mobile

(b) (6)

2017 CY Audit Schedule Audit ID

Confirmed Start Date

(Requested in green)

Confirmed End Date

(Requested in green)

Audit/Review Type

Estimated Number of

Certified Operations - March 21 -

2016

Total Audit

EventsComments

Oth

er N

OP

Divi

sion

St

aff

Patt

y He

ckar

t

Edit h

(Nik

ki) A

dam

s

Mig

uel C

acer

es

Alan

Koh

les

Devo

n Pa

ttill

o

Gra

ham

Dav

is

Rene

e M

ann

Pene

lope

Zuc

k

Lars

Cra

il

Rene

e G

ebau

lt Ki

ng

Robe

rt Y

ang

Jaso

n Lo

pez

Rebe

cca

Clay

pool

Mile

s McE

voy

Cher

i Cou

rtne

y

Bio-Latina - Peru NP7023JLA 23-Jan 27-Jan-16 Renewal 219 1 1 1 Evaluate

Bolicert NP7015LCA 15-Jan 20-Jan-16 Mid-term Audit NA 1 1 1Evaluate

QCS - Florida NP7023NNA 23-Jan 27-Jan-16 Renewal 955 1 1 1 1 GD Auditor in training

IBD - Brazil Renewal 193 1 1 1ETKO NP7051LCA 20-Feb 24-Feb-16 Compliance 1 1CUC NP7044LCA 13-Feb 14-Feb-16 Compliance 1 1

Organic Certifiers - California 13-Mar 17-Mar-16 Renewal 904 1 1 1 1 EvaluationSCS - California 7-Mar 10-Mar-16 Renewal 53 1 1 1 ObservationQAI - California 20-Mar 24-Mar-16 Renewal 1472 1 1 1Bio-Hellas Pre-Decisional 1 1MOCA - California Renewal 54 1 1 1 EvaluationGCIA - Georgia Renewal 110 1 1 1

CCOF - California Renewal 3066 1 1 1OCIA - Nebraska 17-Apr 21-Apr-16 Renewal 784 1 1 1 EvaluationMDA - Maryland 24-Apr 28-Apr-16 Renewal 106 1 1 1 EvaluationOEFFA - Ohio Renewal 972 1 1 1India Recognition 1Taiwan Equivalency 1 1 1TOC Renewal 1 1

STEL - Oregon Renewal 165 1 1 1 EvaluationNMDA - New Mexico Renewal 122 1 1 1 Evaluation

NJDA - New Jersey Renewal 96 1 1 1

NICS - Wisconsin Compliance 847 1 1 1One day compliance audit.

MOSA - Wisconsin Renewal 1684 1 1 1Evaluation

Pro-Cert - Canada Renewal 192 1 1 1

MOFGA - Maine Renewal 483 1 1 1

Bio-Inspecta Compliance 1 1Turkey corn audit

Lacon - Germany Renewal 115 1 1 1

BCS/KIWAS - Germany Renewal 1211 1 1 1

PCO - Penslyvania Renewal 791 1 1 1

10 3 2 32 8 8Total Audits 28 7 6 853 0 29 8

July

February

March

April

May

June

January

NHDAMF - New Hampshire Renewal 131 1 1 1IDALS - Iowa Renewal 413 1 1 1Various Witness Audits - TBD Witness Audits 1 1CA SOP Additional Postpone 2018.MCIA - Minnesota Renewal 244 1 1 1

Canada Equivalency 1 1 1IDA - Idaho Renewal 228 1 1WSDA - Washington Renewal 1082 1 1 1 EvaluationBay State - Massachusetts Renewal 348 1 1 1 EvaluationBAR-O Initial 1 1 1MCCO - Monterrey Renewal 14 1 1

GOA - Ohio Renewal 950 1 1 1MDA - Montana Renewal 187 1 1NOFA - NY - New York Renewal 794 1 1VOF- Vermomt Renewal 588 1 1 1

UDA - Utah Renewal 46 1 1CU - South Carolina Renewal 47 1 1 1ECOCERT - ICO - Indiana Renewal 1076 1 1 1

ECOCERT - France Renewal 472 1 1 1

IMO - Switzerland Renewal 448 1 1 1ICS - North Dakota Renewal 721 1 1 1

Letis - Argentina Renewal 167 1 1 1OIA - Argentina Renewal 398 1 1 1ARG - Argentina Renewal 326 1 1 1 Evaluation

NotesRed Font = NOP travel fundingLead Auditor = Yellow FillSecond Auditor (Limited Scope*) = Green FillSecond Auditor = Orange FillObserver = Gray FillTechnical Expert = Burgundy Fill

* Limited Scope = Typically work associated with the audit will be conducted during the onsite portion of the audit only (i.e. very limited audit work during the pre and post audit period).

December

August

September

October

November

From: Panagl, Aurel (Vienna)To: Lopez, JasonJ - AMSCc: Mann, Renee - AMS; Gebault King, ReneeA - AMS; Hansi, Martin (Vienna)Subject: AW: Contact information for De Trade House KhersonDate: Wednesday, September 09, 2015 6:21:29 AM

Dear Mr. Lopez,I am sorry to inform you that SGS Austria has no more mutual business with this company. Andtherefore no up to date contact information.As far as I know they were transferred to CB ETKO, but after what happened to ETKO they will nowbe certified by another CB, unfortunately we have no information about that.Sorry we couldn’t help you sufficiently.Best regards \ Mit freundlichen GrüßenDipl. - Ing. Aurel PanaglCTS - Food ServicesFachbereichsbetreuer

SGS Austria Controll-Co Ges.m.b.H.Diefenbachgasse 35A - 1150 Wien, Austria

Phone: +43 1 512 25 67 -4403

Von: Lopez, JasonJ - AMS [mailto:[email protected]] Gesendet: Dienstag, 08. September 2015 15:42An: Panagl, Aurel (Vienna)Cc: Mann, Renee - AMS; Gebault King, ReneeA - AMSBetreff: Contact information for De Trade House KhersonDear DI Aurel Panagl,The NOP is currently trying to contact Nikolay Sergheev of the “De Trade House Kherson” in theUkraine, a former SGS NOP certified operation. The contact information we received from SGS uponit’s surrender of NOP accreditation is not a deliverable address. As SGS certifies other organicschemes, I considered the operation may still be an active client of SGS. I would appreciate anyupdated contact information (e-mail, physical address, etc..) SGS may have for Nikolay Sergheev ofthe “De Trade House Kherson” in the Ukraine.Thank you for your prompt attention to my request.

Jason LopezAccreditation ManagerUSDA National Organic Program1400 Independence Ave, SWRoom 2649- South, Stop 0268Washington, DC 20250-0268Office: (202)260-9445www.ams.usda.gov/nopInformation in this email and any attachments is confidential and intended solely for the use ofthe individual(s) to whom it is addressed or otherwise directed. Please note that any views oropinions presented in this email are solely those of the author and do not necessarily representthose of the Company. Finally, the recipient should check this email and any attachments forthe presence of viruses. The Company accepts no liability for any damage caused by any virustransmitted by this email. All SGS services are rendered in accordance with the applicable

SGS conditions of service available on request and accessible athttp://www.sgs.com/en/Terms-and-Conditions.aspx

From: Gebault King, ReneeA - AMSTo: Courtney, Cheri - AMS; Yang, RobertH - AMSSubject: CloudVault and ANSI peer reviewDate: Friday, May 13, 2016 2:57:00 PM

Hi, Cheri and Robert- I recently invited you to the CloudVault folder “NOP Peer Review 2016.” This is the vehicle forsharing documents with the ANSI team for a review of NOP accreditation procedures. In summary, the following documents have been requested as part of the review process:

· NOP Handbook (available online)o General Accreditation Policies and Procedures NOP 2000o Separation of Duties in Certification Decisions NOP 2006o Information Submission Requirements for Certifying Agents NOP 2024o Internal Program Review Requirements NOP 2025o Instruction -- Responding to Non-compliances NOP 2403o Personnel Performance Evaluations NOP 2027o Auditor Criteria NOP 2500o Evaluating Auditor Performance NOP 2501

· NOP Internal Procedures (provided by RGK)o Accreditation Committee Instruction NOP 2012o Accreditation Committee Timeline NOP 2012-1o Accreditation Committee Timeline NOP 2039o Extending Accreditation Activities NOP 2501-1o Auditor-in-Training Evaluation NOP 2501-2

· The following accreditation decisions (certifier files) have been provided as requested byANSI team (provided by RGK):

o BAR-Oo Primus Labs “satellite”o ETKO-Turkeyo Ecocert ICOo TX Dept. of Ag

I am happy to meet with you if you would like more background about the process thus far. Pleaselet me know if you have any questions.

Renée GK


(b) (6)

From: Panagl, Aurel (Vienna)To: Lopez, JasonJ - AMSCc: Mann, Renee - AMS; Gebault King, ReneeA - AMS; Hansi, Martin (Vienna)Subject: AW: Contact information for De Trade House KhersonDate: Wednesday, September 09, 2015 6:21:29 AM

Dear Mr. Lopez, I am sorry to inform you that SGS Austria has no more mutual business with this company.And therefore no up to date contact information.As far as I know they were transferred to CB ETKO, but after what happened to ETKO theywill now be certified by another CB, unfortunately we have no information about that. Sorry we couldn’t help you sufficiently. Best regards \ Mit freundlichen Grüßen Dipl. - Ing. Aurel PanaglCTS - Food ServicesFachbereichsbetreuer

SGS Austria Controll-Co Ges.m.b.H.Diefenbachgasse 35A - 1150 Wien, Austria

Phone: +43 1 512 25 67 -4403

Von: Lopez, JasonJ - AMS [mailto:[email protected]] Gesendet: Dienstag, 08. September 2015 15:42An: Panagl, Aurel (Vienna)Cc: Mann, Renee - AMS; Gebault King, ReneeA - AMSBetreff: Contact information for De Trade House Kherson Dear DI Aurel Panagl, The NOP is currently trying to contact Nikolay Sergheev of the “De Trade House Kherson” in theUkraine, a former SGS NOP certified operation. The contact information we received from SGS upon it’s surrender of NOP accreditation is not a deliverable address. As SGS certifies other organicschemes, I considered the operation may still be an active client of SGS. I would appreciate anyupdated contact information (e-mail, physical address, etc..) SGS may have for Nikolay Sergheev ofthe “De Trade House Kherson” in the Ukraine. Thank you for your prompt attention to my request.

Jason LopezAccreditation ManagerUSDA National Organic Program1400 Independence Ave, SWRoom 2649- South, Stop 0268Washington, DC 20250-0268

Office: (202)260-9445www.ams.usda.gov/nop Information in this email and any attachments is confidential and intended solely for the use ofthe individual(s) to whom it is addressed or otherwise directed. Please note that any views oropinions presented in this email are solely those of the author and do not necessarily representthose of the Company. Finally, the recipient should check this email and any attachments forthe presence of viruses. The Company accepts no liability for any damage caused by any virustransmitted by this email. All SGS services are rendered in accordance with the applicableSGS conditions of service available on request and accessible athttp://www.sgs.com/en/Terms-and-Conditions.aspx

From: Lopez, JasonJ - AMSTo: [email protected]: Mann, Renee - AMS; Yang, RobertH - AMSSubject: Contact information for de Trade House KhersonDate: Friday, September 11, 2015 11:39:00 AM

Dear Dr. Mustafa Akyuz, The NOP is currently trying to contact Nikolay Sergheev of the “De Trade House Kherson” in theUkraine, a former SGS NOP certified operation. The contact information we currently have is not adeliverable address. I was informed that Mr. Sergheev may have become certified with EcologicalFarming Control Organization (ETKO). I would appreciate any updated contact information (e-mail,physical address, etc..) SGS may have for Nikolay Sergheev of the “De Trade House Kherson” in theUkraine. Thank you for your prompt attention to my request.


From: [email protected]: Lopez, JasonJ - AMSSubject: RE: Contact information for de Trade House KhersonDate: Saturday, September 12, 2015 7:51:16 AM

Mr Lopez We are not familiar with the mentioned company and Mr Sergheev. I guess SGS must have all detailsof the operator. As far as I know SGS Moldavia deals with the organic certification processes inUkraine. There the contact person is Mr. Sergiu CroitoruI hope to help you in this way. Sincerely Mustafa Akyuz ETKO/Turkey Details of Mr Croitoru. Sergiu CroitoruGeneral ManagerOrganic and GLOBALGAP Lead AuditorSGS (Moldova) S. A.7, M. Eminescu, StreetMD-2009, Chisinau, Republic of MoldovaPhone: +373 22 22 83 83 Mobile: Fax: +373 22 22 50 66 E-mail: [email protected]

From: Lopez, JasonJ - AMS [mailto:[email protected]] Sent: Friday, September 11, 2015 6:39 PMTo: [email protected]: Mann, Renee - AMS; Yang, RobertH - AMSSubject: Contact information for de Trade House Kherson Dear Dr. Mustafa Akyuz, The NOP is currently trying to contact Nikolay Sergheev of the “De Trade House Kherson” in theUkraine, a former SGS NOP certified operation. The contact information we currently have is not adeliverable address. I was informed that Mr. Sergheev may have become certified with EcologicalFarming Control Organization (ETKO). I would appreciate any updated contact information (e-mail,physical address, etc..) SGS may have for Nikolay Sergheev of the “De Trade House Kherson” in theUkraine.

(b) (6)

Thank you for your prompt attention to my request.


From: Mann, Renee - AMSTo: Lopez, JasonJ - AMSCc: Zuck, Penelope - AMS; Gebault King, ReneeA - AMSSubject: SGS Austria and TOFC surrendered clients follow-upDate: Wednesday, September 02, 2015 6:00:06 PM

Hi Jason –I would like you to work on the follow-up for the SGS Austria and TOFC clients. Please speak withPenny and RGK about these tasks. We will check in on this at our weekly meeting. Thanks,Renee Renee MannAssistant Director, Accreditation and International Activities DivisionUSDA National Organic Program(202) 260-8635Join the NOP mailing list.

From: Davis, Graham - AMSTo: Gebault King, ReneeA - AMSSubject: FW: SGS StuffDate: Tuesday, May 10, 2016 2:55:46 PMAttachments: RE Contact information for de Trade House Kherson.msg

Contact information for de Trade House Kherson.msgAW Contact information for De Trade House Kherson.msgSGS Austria and TOFC surrendered clients follow-up.msgimage002.jpg

Renee- Here is what Jason sent me regarding the two remaining operations formerly certified bySGS. I am just not sure what letter I should send out next in order to close the books on this ACAsurrender. Thanks. Graham Graham DavisAccreditation Manager USDA | NATIONAL ORGANIC PROGRAM1400 Independence Ave SW| 2649-S | Washington DC 20250Desk: 202-692-0047 | Cell:

Join the NOP mailing list

From: Lopez, JasonJ - AMS Sent: Thursday, April 14, 2016 8:44 AMTo: Davis, Graham - AMS <[email protected]>Subject: SGS Stuff

(b) (6)

From: McEvoy, Miles - AMSTo: Courtney, Cheri - AMSCc: Tucker, Jennifer - AMS; Lewis, Paul I - AMS; Gebault King, ReneeA - AMSSubject: FW: thank you for joining us on November 15 at the Pre-NOSB meetingDate: Tuesday, November 08, 2016 5:04:30 AM

Please prepare talking points for these questions as they are under AIA responsibilities. Thanks. From: Abby Youngblood [mailto:[email protected]] Sent: Monday, November 07, 2016 4:52 PMTo: McEvoy, Miles - AMS <[email protected]>Cc: Subject: thank you for joining us on November 15 at the Pre-NOSB meeting Dear Miles,

Thank you for joining us at our Pre-NOSB meeting next week on Tuesday the 15th. I am writing toconfirm that we have you scheduled to take part from 2:30 to 3:30. Are there others from USDA who willbe able to join us? We are planning on a Q&A format, similar to the format we’ve had during the past several meetings. Twoof the topics we would like to discuss are outlined at the end of this message. I will be in touch veryshortly with one or two additional topics. During the meeting, we would like to present each of thesetopics to you, hear your response and have time for some discussion. Here is the general format we havein mind: - 5 min for opening remarks from you- 3 min or less for NOC member to present topic/question- 4 to 5 min for your response- 10 min for discussion If we spend about 15 to 20 minutes on each question, we should be able to finish in the time allotted. We have approximately 50 people planning to attend, including about 20 NOC members, as well as 30others, including farmers, NOSB members, certifiers, animal welfare groups, and organic industrymembers. We appreciate your dedication to organic and your engagement with NOC and others during the meeting.Please do not hesitate to let me know if you have questions. Best Regards,Abby and Steve


While the allowance for the use of non-organic seed in organic production is important forgrowers who lack access to appropriate organic seed, the organic seed requirement isinconsistently enforced. Many would like to see the NOP do more through guidance andregular trainings to create incentives for farms to use more organic seed and to establish aframework for continuous improvement in the use of organic seed.

(b) (6)

How can this guidance be strengthened and what else can the NOP do to supportincreased use of organic seed? How will the NOP support tracking organic seed availabilityby crop type and region on an annual basis?


Over the past few years, there has been a dramatic increase in imports of organiccommodities, especially grains. A key area of concern for U.S. organic grain growers iswhether these increased imports present an opportunity for fraudulently labeled organicproducts to enter the United States, undermining the opportunity for U.S. producers toget a fair price in the market. Long international supply chains may increase theopportunities for fraud due to breaks in the chain of recordkeeping, organic certificationand verification that the USDA organic seal is built upon. The rise of imports from Turkeyespecially raises concern and one Turkish organic certifier, ETKO, has been decertified bythe EU. The NOP took the step of reminding importers of handling regulations on July 13, 2016,but this action is not enough to address the potential for fraud. What plans does the NOP have to address this issue? Will the NOP require importers to becertified by an NOP accredited certifier going forward? What other systems will the NOPput in place to ensure the integrity of shipments of grains and other commodities?

--Abby Youngblood Executive DirectorNational Organic [email protected]: www.NationalOrganicCoalition.orgTwitter: @NationalOrganicFacebook: Facebook.com/NationalOrganicCoalition

(b) (6)

From: Gebault King, ReneeA - AMSTo: Valeriya Staykova; Benoit Dube; Rola Yehia; "[email protected]"Cc: Courtney, Cheri - AMSSubject: 29 April draft minutes US-CFIADate: Monday, May 16, 2016 1:26:00 PMAttachments: 2016 Apr 29 US CAN dvc draft minutes.docx

Dear Valeriya, Please find attached the draft minutes from our recent teleconference held on 29 April 2016. Iwould appreciate it if you and your team could review these draft minutes and provide any edits in“track changes” mode. Kind regards,

Renée



(b) (6)



Time/Location:



1:30 p.m. – 3:00 p.m. Ottawa, CAN


Polycom IP based Videoconferencing system DIAL OR ##OR video.gc.ca#

ISDN based Videoconferencing system DIAL Enter #” when prompted.

By Telephone OR


Purpose:


Agenda






(b) (6)

(b) (6)(b) (6)

(b) (6)

(b) (6)(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)






ii. US conducting our own side-by-side analysis and a desk audit d. Role of “observer” clarification (refer to #6 Plurilateral) e. NOP provided update on Mexico

3. Annual Reports











certificate requirement















iii. d. Pet Food



e. Apiculture







arrangements









10. USDA update on Mexico

a. Onsite assessment is completed and was favorable. b. Working to further develop the arrangement structure over the summer 2016. c. New program has several items to address but USDA is optimistic for establishing



Mexico concludes negotiations with the EU and U.S. b. S. Korea: negotiations with CFIA are in process; S. Korea has assessed CFIA

system; now negotiating terms of the arrangement. c. EU: The equivalency with EU-CAN was renewed; it now includes organic wine

and multi-ingredient products. d. CFIA is working to extend equivalency with CH currently

12. ETKO (Turkey)







Participants





Time/Location:



1:30 p.m. – 3:00 p.m. Ottawa, CAN


Polycom IP based Videoconferencing system DIAL OR # OR video.gc.ca##

ISDN based Videoconferencing system DIAL Ente “#” when prompted.

By Telephone OR


Purpose:


Agenda






(b) (6)

(b) (6)(b) (6)

(b) (6)

(b) (6)(b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)


b. CFIA sent to USDA NOP 18 positive pesticide residue sampling results. The NOP treats these requests for follow-up from the CFIA as complaints (15 deferred; 2 closed; 1 ongoing)

i. Another branch program, the National Chemical Residues Monitoring Program, within the CFIA (independent of the organic program) performs manages the sampling/testing for the CFIA organic program., but The CFIA’s organic program acknowledges that there are issues with timeliness of notices and accuracy completeness of sample information. have occurred.

ii. The CFIA organic program staff may re-evaluate this process and focus on using a risk assessment approach; USDA NOP would be interested in reviewing the CFIA proposed directive.

c. Re-assessment (refer to item #4) i. CFIA provided updated standards and a summary of the key changes side

by side ii. US conducting our own side-by-side analysis and a desk audit

d. Role of “observer” clarification (refer to #6 Plurilateral) e. NOP provided update on Mexico

3. Annual Reports









iii. September : Post-desk audit review and discussion via videoconference iv. Spring 2017: On-site assessment of each program v. Summer 2017: Finalize terms of the USCOEA


certificate requirement ii. USDA is developing a proposed rule to require import certificates for all

product entering the U.S. (not just for equivalence arrangements) iii. CFIA still exploring options; trying to use an existing form if possible; the

organic import certificate proposal is a priority for this fiscal year. iv. Address this item again during equivalency renewal.

5. USCOEA questions

a. COR CB accreditation in Third Country (“Country A” trade scenario) b. Trade route is based on the competent authority to ensure it meets the terms of the











iii. Aquaculture products are not under the scope of the current Organic Products Regulations in Canada.

d. Pet Food






i. New Executive Director, Food Import/Export and Consumer Protection Directorate: Lyzette Lamondin

i.ii. New National ManagerDirector, Strategies & PlanningConsumer Protection and Market Fairness Division: Kathy Twardek

ii.iii. New Program Specialist, Labeling, Organic & Packaging: David Ladd b. New Canadian Organic Standards (COS) released November 25, 2015 c. Reviewing comments currently and expecting the Safe Food for Canadians

rRegulations to go to out pre-publication for public comment in Canada Gazette, Part I in late 2016.

i. Anticipating that aquaculture will come be included into the scope of the organic part of the regulations

ii. No changes expected for renegotiations of equivalencies d. CFIA attended BioFach and presented a session on plurilateral/multilateral

arrangements












Mexico concludes negotiations with the EU and U.S. b. S. Korea: negotiations with CFIA are in process; S. Korea and the has assessed

CFIA have assessed each other’s system; now negotiating terms of the arrangement.

c. EU: The EU-CAN equivalency with EU CAN was renewedexpanded; it now includes organic wine and Canadian multi-ingredient products containing imported ingredients.

d. CFIA is currently working to extend the equivalency with CH currentlysimilarly as with the EU

12. ETKO (Turkey)







Participants

Canada Rola Yehia National Manager Canadian Food Inspection Agency (CFIA) Valeriya Staykova Lead Auditor Canadian Food Inspection Agency (CFIA) Benoit DubeDubé Regulations and Standards Officer Canadian Food Inspection Agency (CFIA) U.S. Department of Agriculture Miles McEvoy Deputy Administrator National Organic Program (NOP) Agricultural Marketing Service (AMS) Cheri Courtney Director, Accreditation and International Activities Division National Organic Program (NOP) Agricultural Marketing Service (AMS) Renée Gebault King Accreditation Manager National Organic Program (NOP) Agricultural Marketing Service (AMS) Kelly Strzelecki Senior Trade Advisor, Processed Products & Technical Regulations Division Foreign Agriculture Service (FAS)


From: Gebault King, ReneeA - AMSTo: McEvoy, Miles - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: Canada comments on meeting minutesDate: Thursday, June 02, 2016 9:41:00 AMAttachments: CFIA ACIA - #8203212 - v1 - 2016 APR 29 US CAN dvc minutes.DOCX

Hi Team! Attached please find the draft minutes from our teleconference with Canada (29 April 2016). Thisversion includes some edits, mostly added details or clarifications. Please review and let me know ifyou have any concerns or questions. I would like to finalize these by Friday, 10 June if possible. Thank you!

Renée GK


(b) (6)



Time/Location:



1:30 p.m. – 3:00 p.m. Ottawa, CAN


Polycom IP based Videoconferencing system DIAL OR # OR video.gc.ca##


By Telephone OR


Purpose:


Agenda

1. Welcome and Introductions a. Connected via teleconference. b.





(b) (6)

(b) (6)

(b) (6)(b) (6)

(b) (6)(b) (6) (b) (6)

(b) (6)

(b) (6)

(b) (6)

(b) (6)






ii. US conducting our own side-by-side analysis and a desk audit d. Role of “observer” clarification (refer to #6 Plurilateral) e. NOP provided update on Mexico f. NOP provided information on SunOpta/non-GMO

3. Annual Reports










b. Organic import certificates status update

i. USDA and CFIA agreed last year to change the attestation to an import certificate requirement










on this issue. ii. T task force report to the NOSB will be completed in June; NOP expects





iii. d. Pet Food










arrangements


organic program. NOP met with OMRI during NOSB meetings this week: OMRI discussed trying to provide material review services in Canada (per “Input Verification under COR” memo from CFIA). OMRI wants to confirm that OMRI ISO 17065 accreditation is accepted (per CFIA memo).

b. CFIA explained that ISO 17065 is only for certification bodies to certify organic products under COR; CFIA cannot recognize or accredit OMRI under their system to ISO 17065; OMRI may be used by CBs for material review only (per CFIA memo requirement #3) as an accepted third party, but OMRI cannot refer to accreditation to COR. CFIA will evaluate this situation further.







Participants



From: Gebault King, ReneeA - AMSTo: McEvoy, Miles - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: Canada meeting, draft minutesDate: Monday, May 02, 2016 1:25:00 PMAttachments: 2016 Apr 29 US CAN dvc draft minutes.docx

Hi, Team! Attached are the draft minutes from last Friday’s teleconference with Canada. I would appreciate it ifyou could review these minutes and provide feedback (track changes mode). I would like to send the minutes to Canada by the end of the week if possible. Thanks!

Renée GK


(b) (6)

EU – U.S. Organic Working Group

September 15, 2015 – by Videoconference

Time/Location:

9:00 – 10:00 a m. Washington D.C.

• 1605-S, USDA South Building, 1400 Independence Ave.

3:00 p m. – 5:00 p.m. Brussels, BEL

• Only H.323 compatible system (Skype not supported) • From a Tamberg machine: [email protected]; [email protected] • From a Polycomm machine: 147.67.16.68##72981

Purpose:

Ongoing discussions for maintenance of the equivalence agreement between the US and EU.

Agenda

1. Welcome and Introductions

2. Technical Barriers to Trade (TBT) discussions a. US and EU representatives agreed that EU organic program falls within the scope

of the World Trade Organization (WTO) Technical Barriers to Trade (TBT) Agreement (not the WTO Sanitary and Phytosanitary (SPS) Measures). The US provided a draft WTO TBT notification (under Article 10) of the US-EU arrangement to the EU staff; the EU agrees with the substance of the document.

b. The EU would like to conduct a joint notification with the US; the US agreed. c. J. Doherty suggested the US and the EU inform the TBT committee of the

notifications during their meeting in Geneva on November 4-5, 2015; the US will submit the notification to the WTO within the next 2-3 weeks and share the statement with the Committee.

d. Switzerland and Korea have already agreed to notify the US equivalence arrangements; the US will be notifying the WTO on behalf of Canada and Japan.


a. The draft of the US concepts paper was shared and comments requested from EU colleagues. The EU staff will need more time to review the document. There was also discussion about the potential launch or sharing of the plurilateral paper/process at BioFach 2016 or other venues with potential partner countries.

b. Determine next steps i. Mid-October: the EU will share ideas on US concepts paper.

ii. Mid-October: the EU will propose meeting ideas for workshop/launch.

4. Status update on current US and EU equivalency negotiations a. Mexico

i. US: Equivalency negotiations continue. The NOP has shared documents from their program; Mexican officials have accompanied NOP staff on audits of certification bodies in the US. The NOP is still evaluating the Mexican program via desk audit; there will be additional meetings to discuss issues this fall. The US agreed to share the Mexican program assessment report with the EU once it is conducted.

ii. EU: Now starting technical discussions of Mexico legislation. b. New Zealand

i. US: Currently have recognition agreement; New Zealand has requested equivalency arrangement (with export standards only); US is currently in discussions with New Zealand and is planning an onsite audit in 2016

ii. EU: Arrangement with New Zealand since 2002 and the scope covers unprocessed and processed plant products, live animals, and vegetable plant products for propagation; since 2014 had recognition of wine standard. The arrangement is bilateral but is primarily a program for New Zealand exporters; the EU receives ~12,000 tons/year of product from New Zealand. There have not been any particular nonconformities thus far; the EU/FVO has never conducted an audit of New Zealand (they are considered low-risk). New Zealand has some concerns about Pacific Islands that are not covered by arrangement.

c. Taiwan i. US: Received request for equivalency arrangement and is currently

conducting a “side by side” analysis. The US will share this information with the EU as process unfolds.

ii. EU: There are discussions about Taiwan re-applying to the EU, but one major issue is that Taiwan does not recognize all EU member states that joined after 2004.

d. Others? i. India

1. US: The current recognition arrangement has significant issues; the US is continuing to work with India over the next 6 months-1 year to resolve/change arrangement. The NOP appreciated being able to participate in the recent FVO audit of India.

2. EU: Nothing to share as the final report is not yet completed. ii. Chile

1. EU: equivalency expected in 2016. iii. Ecuador

1. EU: equivalency expected in 2016. iv. Canada (CA)

1. FVO will conduct an audit in CA from September 21 to October 2, 2015in CA soon.

2. CA would not allow US observers to participate in the FVO audit “because they want to better understand the role of the observer and want clearly defined roles.”

3. Both sides discussed the need to develop criteria on the role of observers.

5. Status update on EU standards review from March

a. Update: The Council of Agricultural Ministers proposal common position from was adopted in June 2015 is still active, butand next step is the adoption of the European Parliament report they are awaiting a report from the EU Parliament, which is expected in October 2015. Next it is likely that meetings and negotiations will start, but they don’t expect to finish before Christmas 2015. This is a political priority and visibility ist expected to remain high.

6. Aquaculture standard:

a. The draft is currently under review. b. The US expects publication in November 2015.

7. Next Organic Working Group meeting

a. Set for Thursday, 12 November 2015 b. Update: meeting postponed to Monday, 25 January 2016.

EU – U.S. Organic Working Group

January 25, 2016 – by Videoconference

Time/Location:

9:00 – 11:00 a.m. Washington D.C., USA

• Room 305, Winder Building, 600 17th St. NW • Conference Room Phone: +1 202.395.9613 • IP 65.207.24.231 (Up to 1Mbps)

3:00 p.m. – 5:00 p.m. Brussels, BEL

• Only H.323 compatible system (Skype not supported) • From a Tamberg machine: [email protected]; [email protected] • From a Polycomm machine: 147.67.16.68##72981

Purpose:

Ongoing discussions for maintenance of the equivalence agreement between the US and EU.

Agenda

1. Welcome and Introductions

2. Plurilateral trade arrangements a. Draft concept papers from EU and US

i. Discuss feedback and synthesis of US and EU proposals ii. Timeline moving forward

b. Discuss joint meeting on plurilateral arrangements with potential partner countries i. Location and potential dates

ii. List of countries to invite

3. US-EU trade arrangement questions a. Private label clarification: import of EU certified product for USDA certified

private label company b. Other trade clarifications?

4. Update on WTO TBT notifications (Geneva meeting November 2015)

a. US-EU joint notification b. Other notifications

i. Switzerland and Korea on behalf of the US ii. US on behalf of Canada and Japan

5. Update on ongoing US and/or EU equivalency negotiations a. Mexico b. New Zealand c. Taiwan d. Chile e. Ecuador f. India g. Canada g.h.Colombia

6. Update on ETKO (Turkey)

7. Update on EU standards review/report from EU Parliament

8. Update on US aquaculture standards release

9. Other topics?

10. Next Organic Working Group meeting

EU – U.S. Organic Equivalence Discussions

February 15, 2015 – by Videoconference

Participants

European Union Joao Onofre Assistant to the Director General DG Agriculture and Rural Development Manuel Rossi-Prieto Policy Officer – International Sector DG Agriculture and Rural Development U.S. Department of Agriculture Miles McEvoy Deputy Administrator National Organic Program (NOP) Agricultural Marketing Service (AMS) Cheri Courtney Director, Accreditation and International Activities Division National Organic Program (NOP) Agricultural Marketing Service (AMS) Kelly Strzelecki Senior Trade Advisor, Processed Products & Technical Regulations Division Foreign Agriculture Service (FAS) Office of the U.S. Trade Representative Julia Doherty Senior Director, SPS and Agricultural Affairs Office of the U.S. Trade Representative (USTR) Executive Office of the President

From: Doherty, JuliaTo: Gebault King, ReneeA - AMS; Strzelecki, Kelly - FAS; Courtney, Cheri - AMS; McEvoy, Miles - AMSSubject: FW: EU-US meetings, draft minutes and draft agendaDate: Tuesday, January 19, 2016 5:51:37 PMAttachments: image001.png

image002.png2016 Jan 25 draft agenda DVC EC.docx2015 Sep 15 agenda DVC draft minutes USDA EC.docx

Are y’all available to pre-game what we say to the EU on plurilateral strategy?Also, in case you missed it, Argentina has notified its proposed organic regs to the WTO.

From: [email protected] [mailto:[email protected]] Sent: Monday, January 18, 2016 5:04 AMTo: [email protected]; [email protected];[email protected]: [email protected]; [email protected]; [email protected];Doherty, JuliaSubject: RE: EU-US meetings, draft minutes and draft agendaDear Renée,You will find attached the draft minutes from 15 September slightly modified and the draft agendafor next week's meeting with the addition of Colombia for the discussion on ongoing equivalencynegotiations.Both documents can become final for us.On the plurilateral agreement, we are finalising our comments and will send them to you as soon aspossible.Best regardsManuel ROSSI PRIETOPolicy Officer – International Sector

European CommissionDG Agriculture and Rural DevelopmentDirectorate B. Multilateral Relations, Quality PolicyUnit B.4. Organics

L130 03/224B-1049 Brussels/Belgium+32 2 295 21 [email protected]

From: Gebault King, ReneeA - AMS [mailto:[email protected]] Sent: Thursday, January 14, 2016 8:16 PMTo: ROSSI PRIETO Manuel (AGRI); ONOFRE Joao (AGRI);(b) (6)

Cc: McEvoy, Miles - AMS; Courtney, Cheri - AMS; Strzelecki, Kelly - FAS; Doherty, JuliaSubject: EU-US meetings, draft minutes and draft agendaDear Colleagues,We are looking forward to the video conference scheduled for Monday, 25 January 2016(9:00-11:00 am Washington/3:00-5:00 p.m. Brussels).In preparation for the virtual meeting, we would appreciate your review/input on the(attached) following items:

· Draft minutes from our 15 September 2015 video meeting· Draft agenda for 25 January 2016 meeting (connection information provided)

If you have any additional questions or concerns, please let me know.Kind regards,

RenéeRenée Gebault King, Ph.D.Accreditation ManagerOffice: 202.690.1312 | Mobile: [email protected] National Organic Program | 1400 Independence Ave SW | Room 2649-South, Stop 0268Washington, D.C. 20250-0268 | Tel: 202.720.3252 | Fax: 202.205.7808 | www.ams.usda.gov/nopSubscribe to the USDA’s Organic Insider to receive updates in your e-mail!

(b) (6)

From: McEvoy, Miles - AMSTo: Michael, Matthew - AMSCc: Gebault King, ReneeA - AMSSubject: FW: US-EU DVC draft minutesDate: Monday, March 21, 2016 5:51:30 PMAttachments: 160202 OWG DRAFT minutes.doc

Miles

From: Gebault King, ReneeA - AMS Sent: Friday, March 18, 2016 3:45 PMTo: McEvoy, Miles - AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Strzelecki, Kelly - FAS <[email protected]>; Doherty,Julia <[email protected]>Subject: US-EU DVC draft minutes Hello, Team- Attached please find the draft minutes from the 2 Feb. 2016 DVC with the EU. Please review at your earliest convenience. Enter any comments or edits in “track changes” mode. Thank you!

Renée GK


(b) (5)

(b) (6)



Note to the file







February-April:





2


April-July


September-October








On Mexico, US informed that an on-site inspection will take place in March. The goal is to conclude negotiations by fall 2016. EC explained that it will try to close its negotiations immediately after and asked US to share the equivalency assessment.


On Taiwan, US informed about a peer review that will take place in US in March. Not full equivalency expected. US aim to ensure products access to Taiwan. EC referred to alternative solutions as the recognition of Taiwan's control authority.



3

5. Update on ETKO






8. AOB



Manuel ROSSI PRIETO

From: Gebault King, ReneeA - AMSTo: Wilburn, Tammie - AMSCc: Michael, Matthew - AMSSubject: FW: Official complaint and OIG letter filed on behalf of Date: Friday, September 16, 2016 3:46:00 PMAttachments: OIG organic imports letter final090116.doc

NOP Complaint090716.docx

Hi Tammie, Per Miles’ request, could you please provide a summary of this investigation? I would appreciate it ifyou could have something by noon on Thursday, 22 September. Contact me if you have questions or concerns. Thanks so much! Kind regards,

Renée

Renée Gebault King, Ph.D.Acting Chief of StaffUSDA National Organic Program

Office: 202.690.1312 | [email protected]

From: McEvoy, Miles - AMS Sent: Monday, September 12, 2016 1:24 PMTo: Tucker, Jennifer - AMS <[email protected]>Cc: Gebault King, ReneeA - AMS <[email protected]>Subject: FW: Official complaint and OIG letter filed on behalf of Please ask Tammie to provide summary of current investigation. Thanks.

From: Rakola, Betsy - AMS Sent: Friday, September 09, 2016 3:28 PMTo: McEvoy, Miles - AMS <[email protected]>; Starmer, Elanor - AMS<[email protected]>; Michael, Matthew - AMS <[email protected]>Subject: FW: Official complaint and OIG letter filed on behalf of FYI From: Sent: Friday, September 09, 2016 3:21 PMTo: Rakola, Betsy - AMS <[email protected]>Subject: Official complaint and OIG letter filed on behalf of Hi Betsy,

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

To: Miles McEvoy, USDA AMS Deputy Administrator Attn: [email protected] Date: September 7, 21016 From: Re: Filing a formal complaint on behalf of and its organic producer members regarding potential fraudulent organic grain imports. During the third week in May, 2016 the Nakagowa, a cargo ship docked in Burns Harbor, Indiana on Lake Michigan with a cargo of 450,000 bushels of supposedly organic corn. Further reports indicate that additional ships docked on the East Coast (Baltimore Harbor) with similar grain cargos during May, 2016 The Nakagowa took on its cargo from a Turkish port raising even further questions about the “organic integrity” of the shipment. This resulted in dumping up to 1.2 million bushels of corn on the U.S. organic market within a month.

(Source: Kramer and Eddy)

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

The ships port of origin was traced to a Turkish port on the Black Sea.

A 2016 report by USDA’s Foreign Agriculture Service summarized the potential for fraudulent activity in the Turkish organic sector:

“According to a EUROPOL report, some Turkish companies have been involved in relabeling or repackaging products as organic and bringing the counterfeit products into the European Union, even though the products do not meet the EU’s organic standards. Reports from the Research Institute of Organic Agriculture (FiBL) in 2013, Eurofins Scientific in 2012, the Cornucopia Institute in 2013 and the French Ministry of the Economy in 2015 uncovered fraud or unapproved production methods in organic products from Turkey. There have also been instances where a few Turkish companies were found to have been using fraudulent organic certificates. Turkish news articles report that consumers may be misled by conventional products that are marketed as organic, mostly in open air bazaars or independent stores where a vendor could more easily sell a fake organic product. Although inspections and transparency in the Turkish organic food sector are improving, the integrity of organic farming, production, shipping and marketing is not always guaranteed.”1

One Turkish organic certifier, ETKO, has been decertified by the EU.2 The introduction of additional testing regimes in the EU has reportedly led some traders to prefer to ship to non-EU destinations (including the United States), as there is less risk of rejection in U.S. markets.3 As the organic market grows rapidly around the world, resulting shortages in the supply of various commodities can create a tempting situation for those who do not value the integrity of the organic standards and see a potential to ship products fraudulently labeled as organic. The potential for fraud is being acknowledged by some participants in the organic sector, with the establishment of an Anti-Fraud Initiative to “improve cross border communication among inspection and certification bodies, trade companies, label organizations and authorities to strengthen organic integrity.”4 The fact that fraud is a serious enough concern to trigger the creation of this network, and international workshops with titles such as “Best practice examples to guarantee integrity of organic exports from Turkey,”5 should provide sufficient motivation to the NOP to dedicate more effort to this issue. This type of shipment and its port of origin that USDA FAS has already cited for issues of organic fraud also raises questions about the traceability back to individual farms at the country of origin; the same standards as U.S. producers are required to meet. There is also the question of proper documentation and traceability at the U.S. port of entry. On behalf of , its six member cooperatives and certified organic producers, this formal complaint is filed with your office to protect the organic integrity of U.S. producers under the NOP program and their markets. Sincerely,

1 USDA Global Agriculture Information Network. “Report # TR601, Turkish Organic Market Overview.” January 26, 2016.

2 IOAS. “IOAS withdraw ISO 65 accreditation of ETKO Turkey.” May 25, 2016. 3 Personal communication. Email to from a U.K. organic farmer-owned company. August 8, 2016. 4 Anti-Fraud Initiative. http://www.organic-integrity.org/ 5 Anti-Fraud Initiative. “Meetings and Events.” http://www.organic-integrity.org/meetings/#c2716

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

• During the first six months of 2016, 12 countries exported organic soybeans (except

seed) to the United States. Turkey was the leading exporter, followed by India, and Ukraine. In 2015, Turkey was the sixth largest exporter.

• During the first six months of 2016, there was a dramatic increase in the dollar value of

imported organic soybean (except seed) imports from Turkey, with more than thirty-six times the value of imports from Turkey in the first six months of 2016 than the same time period in 2015.

• From 2013 to 2015, the dollar value of imported organic yellow dent corn (except seed)

more than tripled, from $36 million to $112 million.

• During the first six months of 2016, 8 countries exported organic yellow dent corn (except seed) to the United States. Turkey was the leading exporter, followed by Romania and the Netherlands.

• During the first six months of 2016, the dollar value of imported organic yellow dent

corn (except seed) nearly doubled from the same time period in 2015.

• During the first six months of 2016, there was a dramatic increase in the dollar value of imported organic yellow dent corn (except seed) from Turkey, with more than five times the value of imports from Turkey in 2016 than the same time period in 2015. The imports from Turkey during the first six months of this year were close to double the value from Turkey for the entire year of 2015. 3

As organic exports grow, so do concerns about the potential for fraudulent organic products to enter the United States, due to lack of inspections and the opportunities for fraud that occur in more complicated supply chains. These long international supply chains increase the opportunities for breaks in the chain of recordkeeping, organic certification and verification that the USDA organic seal is built upon. We are aware that your audit focuses on the agreement between the United States and the EU. But there are connections between major exporters to the United States, such as Ukraine and Turkey, and the EU. Specifically, the rise of imports from Turkey raises concern. A 2016 report by USDA’s Foreign Agriculture Service summarized the potential for fraudulent activity in the Turkish organic sector:

“According to a EUROPOL report, some Turkish companies have been involved in relabeling or repackaging products as organic and bringing the counterfeit products into the European Union, even though the products do not meet the EU’s organic standards. Reports from the Research Institute of Organic Agriculture (FiBL) in 2013, Eurofins Scientific in 2012, the Cornucopia Institute in 2013 and the French Ministry of the Economy in 2015 uncovered fraud or unapproved production methods in organic products from Turkey. There have also been instances where a few Turkish companies were found to have been using

3 Data compiled from USDA’s Economic Research Service.

fraudulent organic certificates. Turkish news articles report that consumers may be misled by conventional products that are marketed as organic, mostly in open air bazaars or independent stores where a vendor could more easily sell a fake organic product. Although inspections and transparency in the Turkish organic food sector are improving, the integrity of organic farming, production, shipping and marketing is not always guaranteed.”4

One Turkish organic certifier, ETKO, has been decertified by the EU.5 The introduction of additional testing regimes in the EU has reportedly led some traders to prefer to ship to non-EU destinations (including the United States), as there is less risk of rejection in U.S. markets.6 As the organic market grows rapidly around the world, resulting shortages in the supply of various commodities can create a tempting situation for those who do not value the integrity of the organic standards and see a potential to ship products fraudulently labeled as organic. The potential for fraud is being acknowledged by some participants in the organic sector, with the establishment of an Anti-Fraud Initiative to “improve cross border communication among inspection and certification bodies, trade companies, label organizations and authorities to strengthen organic integrity.”7 The fact that fraud is a serious enough concern to trigger the creation of this network, and international workshops with titles such as “Best practice examples to guarantee integrity of organic exports from Turkey,”8 should provide sufficient motivation to the NOP to dedicate more effort to this issue. The dramatic increases in imported organic grains are having impacts on the potential for U.S. organic farmers to sell their products for a fair price:

• One major international grain company attempting to make inroads into the U.S. domestic organic market recently told NFOrganics and member organization marketer that he needed to get the prices for organic grain he was offering for sale down to the price they could pay for imported grain.

• Merle Kramer, Midwest Organic Farmers Coop organic grain marketer notes “many

larger buyers of organic corn contracting 50,000 bushels from import brokers offer local farmers 20%-25% less then what they pay for imports, often not having room in their bins to buy domestic corn putting financial pressure on those farmers not being able to sell when they need cash.”

• executive director had discussions with a major organic grain

marketer in Ontario, Canada. The firm markets grain into U.S. markets as well as Canada. The marketer confirmed that in recent months any imported shipment with the semblance of “organic” in the documentation has been sold as organic, no questions asked as to the origin.

4 USDA Global Agriculture Information Network. “Report # TR601, Turkish Organic Market Overview.” January 26, 2016. 5 IOAS. “IOAS withdraw ISO 65 accreditation of ETKO Turkey.” May 25, 2016. 6 Personal communication. Email to , from a U.K. organic farmer-owned company. August 8, 2016. 7 Anti-Fraud Initiative. http://www.organic-integrity.org/ 8 Anti-Fraud Initiative. “Meetings and Events.” http://www.organic-integrity.org/meetings/#c2716

(b) (6), (b) (7)(C)

(b) (6), (b) (7)(C)

(b) (6)

(b) (6), (b) (7)(C)

From: Glasgow, David - AMSTo: McEvoy, Miles - AMSCc: Jones, Samuel - AMS; Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Courtney, Cheri - AMS; Summers,

Bruce - AMS; Wood, Peter - AMSSubject: Re: Flag - FOIA releaseDate: Thursday, February 09, 2017 6:34:52 PM

Got it. Thanks

Sent from my iPhone

On Feb 9, 2017, at 6:01 PM, McEvoy, Miles - AMS <[email protected]> wrote:

The records were released yesterday.Miles

From: Glasgow, David - AMS Sent: Thursday, February 09, 2017 5:44 PMTo: McEvoy, Miles - AMS <[email protected]>; Jones, Samuel - AMS<[email protected]>Cc: Tucker, Jennifer - AMS <[email protected]>; Gebault King, ReneeA -AMS <[email protected]>; Courtney, Cheri - AMS<[email protected]>; Summers, Bruce - AMS<[email protected]>; Wood, Peter - AMS <[email protected]>Subject: RE: Flag - FOIA release Thank you for the heads up, and the background and TPs. The records have already been released? Or, are about to be released? We’ll let you know if calls come in here. Dave

From: McEvoy, Miles - AMS Sent: Thursday, February 09, 2017 2:56 PMTo: Glasgow, David - AMS; Jones, Samuel - AMSCc: Tucker, Jennifer - AMS; Gebault King, ReneeA - AMS; Courtney, Cheri - AMS; Summers,Bruce - AMSSubject: Flag - FOIA release Sam and David – We have a quick media flag for you. Topline Summary: Due to a release of records through the FOIA process, there may bepress inquiries or articles raising concern about the compliance status of USDAaccredited organic certifier ETKO, and more broadly, organic grain imports into the U.S.

from Turkey, where ETKO is based. Background: ETKO (Ecological Farming Control Organization) is a USDA accreditedorganic certifier based in Turkey; the organization was also previously accredited underthe EU and Canada. Based on compliance concerns identified through our standardcertifier oversight processes, the National Organic Program issued a Notice of ProposedSuspension to ETKO in late 2015. To resolve the Notice, the NOP and ETKO reached asettlement agreement in mid-2016, in which ETKO agreed to take specific actions tomaintain compliance in the future. There is industry attention on ETKO because of the industry’s broader concern aboutthe organic integrity of grains coming from Turkey. USDA is investigating theseconcerns in a number of ways, including investigations and heightened oversightmechanisms in the areas of interest. One particularly concerned organization, OFARM(Organic Farmers’ Agency for Relationship Marketing), requested records related toETKO’s Notice of Proposed Suspension and subsequent settlement agreement with theNOP. The documents provided to OFARM consisted of:

1. ETKO’s appeal of its Notice of Proposed Suspension of Accreditation plus exhibits2. Additional Information (“Developments”) with attachments since the appeal was

filed, which include the NOP Noncompliance Audit and Review Process Reports,emails, and ETKO Corrective Action Plans

3. The NOP Appeals Team case analysis documents4. The settlement agreement (also posted online)

We have a second FOIA request related to ETKO from the Wall Street Journal – oncethese records are ready for release, they should come to you from the FOIA officeautomatically since all requests from the media are supposed to be 1) flagged “highpriority” by the AMS FOIA Officer and 2) be given to AMS Public Affairs before beingreleased to the requester. General Talking Points Organic regulatory structure

All organic products sold, labeled or represented as organic in U.S. must complywith USDA organic regulations.

All imports must be certified by an AMS authorized certifying agent unlessimported from countries where we have an equivalency arrangement

Organic equivalency arrangements create new export markets that benefit U.S.producers and processors. AMS has equivalency arrangements with Canada, theEuropean Union, Japan, Korea, and Switzerland.

Organic grain coming to the U.S. from Turkey must be certified by AMSaccredited certifier

Certifiers must comply with USDA accreditation and certificationrequirementsAMS conducts periodic audits of certifiers around the world

Turkish organic imports

The Agricultural Marketing Service has received complaints alleging that non-organic corn and grains are being imported from Turkey as organic, in violationof the USDA organic regulations.

Some of the complaints reference Foreign Agriculture Service data, provided bythe Turkey Ministry of Agriculture, Food and Livestock (MINFAL), showing thatexports of organic grain from Turkey exceed domestic grain production.

This data, in itself, does not demonstrate noncompliance. We have determinedthat organic grain is being consolidated in Turkey that is coming from othercountries in Eastern Europe. Additional evidence collected since the complaintswere filed warrants continued investigation.

On 10/1/16, asked USDA-OIG to investigate, orto include in its ongoing audit of organic equivalency agreements, organic grainimports, and specifically those from Turkey. OIG referred the complaint to AMS-NOP to investigate.

The NOP is actively investigating these complaints and will initiate enforcementaction where warranted and appropriate. The NOP is working with its Federalpartners with oversight authority over imports in investigating these complaints.Because these investigations are ongoing, we cannot comment on them in anydetail.

ETKO

· ETKO is an AMS accredited certifier based in Turkey. ETKO certifies 34operations in Turkey, Ukraine, and South Korea under the USDA organicregulations.

· A settlement agreement was established in 2016 that requires implementationof corrective and preventative actions by ETKO to address findings fromprevious audits.

· AMS conducted an audit in Ukraine in 2016. An AMS audit in Turkey isscheduled for February 2017.

Miles McEvoy

(b) (6), (b) (7)(C)

Deputy AdministratorNational Organic Program

renée - cornucopia institute · note to the file . subject: minutes of the us-eu organic working...

Documents